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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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