Estate of Augusta Porter Forbes - Page 34




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          partnerships.  Based on this information, and taking into                   
          consideration the specific characteristics of the subject                   
          property, possible intra-family conflicts, and other factors                
          adversely affecting the marketability of the two undivided                  
          interests in the subject property, Lawton concluded that a                  
          valuation discount of 30 percent is appropriate.                            
               Hultquist, petitioner’s other expert, concluded that the               
          fair market value of the two undivided interests in the subject             
          property as of decedent’s date of death was $720,000, based on              
          the correlated present value of net annual income streams that he           
          projected from hypothetical partitions or forced sales of the               
          subject property under various scenarios.  Hultquist assumed that           
          the QTIP trust’s undivided interests included the value of pecan            
          orchards but not the value of any timber.  Because this                     
          assumption is contrary to our previous determination that the               
          QTIP trust’s undivided interests included no beneficial interest            
          in the pecan orchards, his $720,000 estimate of discounted fair             
          market value is of little utility.                                          
               Because Hultquist’s $720,000 estimate of the discounted fair           
          market value is approximately 36 percent less than what Hultquist           
          assumed to be the undiscounted fair market value of the undivided           
          interests in the subject property (again assuming that pecan                
          orchards but not timber are included), petitioner argues that a             
          36 percent discount rate is appropriate.  We disagree.  We are              






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