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discounts for both lack of control and lack of marketability for
minority interests in syndicated limited partnerships. The
May/June 1994 issue contained data regarding the sale of limited
partnership interests during the 60-day period ended May 31,
1994.
The estate argues that Burns’ conclusion, which is based on
data found in the May/June 1995 issue, is flawed because such
information was not available on January 1, 1995, the date the
gift was made. The estate contends that, since a gift of
property is valued, pursuant to section 2512(a), as of the date
of the transfer, posttransfer data cannot affect our decision.
However, Burns does not use the posttransfer data to prove
directly the value of the transferred interests. Instead, he
uses the May/June 1995 issue to show what value would have been
calculated if, on January 1, 1995, decedent had looked at
transactions involving the sale of interests in similarly
situated partnerships occurring at that point in time. Data
regarding such transactions involving similarly situated
partnerships were available on the valuation date. Therefore,
the data available in the May/June 1995 issue are relevant as
they provide insight into what information would have been found
if, on January 1, 1995, decedent had looked at transactions
occurring on or near the valuation date.
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