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when applied in large numbers of cases, although discrepancies
inevitably arise in individual cases.” Bank of Cal. v. United
States, supra at 760. Moreover, the experts did not provide an
opinion as to the application of the tables with regard to
annuities but merely valued the partnership as though the lottery
payments’ lack of marketability, or other circumstances,
warranted a departure from the tables. As noted above, we have
already addressed the issue of whether the lack of marketability
inherent in the lottery payments would warrant departure.
The facts here are substantially similar to those in Estate
of Gribauskas v. Commissioner, 116 T.C. 142 (2001). The only
significant factual difference is that here a partnership, rather
than an individual, owned the right to receive the lottery
payments. Here, decedent won the lottery and shared the prize
with Newby. The lottery payments could not be assigned or
transferred without a court order, they could not be distributed
in one lump sum, and they were funded through investments in U.S.
Government bonds. Additionally, the valuation dates are similar
with regard to the applicable statutes, regulations, and caselaw.
In the context of resolving the narrow dispute as framed by
the parties concerning the value of the partnership’s right to
the lottery payments, there is no difference between a right to
receive lottery payments that is owned by a partnership in which
decedent owned an interest and an identical right to receive
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