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discount is typically applied. * * * The value of an
annuity * * * exists solely in the anticipated
payments, and inability to prematurely liquidate those
installments does not lessen the value of an
enforceable right to $X annually for X number of years.
As we concluded in Estate of Gribauskas v. Commissioner, 116
T.C. at 161, 163, when the asset to be valued is one for which
the tables are generally employed, mere illiquidity and/or lack
of marketability of the asset does not lead to, or create, an
unreasonable result requiring an alternative valuation method.
In Estate of Gribauskas we found that a fixed stream of
lottery payments, subject to minimal risk of default, was a
private annuity. Tabular valuation did not lead to an
unrealistic and unreasonable result merely because the annuity,
lacking a corpus from which to draw upon, was unmarketable. The
estate now asserts arguments similar to those of the taxpayer in
Estate of Gribauskas; however, the estate has not shown any
significant fact that would distinguish Estate of Gribauskas.
Moreover, in Estate of Gribauskas, after a review of the cases
where departure was permitted, we opined that “those [cases]
permitting departure have almost invariably * * * [with the
exception of Estate of Shackleford v. United States, supra,]
required a factual showing that renders unrealistic and
unreasonable the return or mortality assumptions underlying the
tables.” Id. at 161 (and the cases cited thereat).
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