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installments here exhibit characteristics consistent with rights
properly valued under the section 7520 tables. Moreover,
respondent alleges that neither any general regulatory exceptions
nor particular features such as lack of marketability permit
departure from the tables in the circumstances of this case.
Hence, in essence the parties agree that the value of the
lottery installments is to be included in decedent’s gross estate
and that the appropriate methodology for ascertaining such value
is to discount the stream of payments to present value. They
advance opposing theories, however, for arriving at the relevant
discount rate. Section 7520 mandates use of a 9.4-percent
discount rate for annuities valued as of December 3, 1994, and
respondent contends that this statute is applicable to the facts
before us. In contrast, the estate argues that the discount rate
should be determined by consideration of what a willing buyer
would pay a willing seller for the asset at issue and, further,
apparently finds that a discount rate of approximately 15
percent, adjusting for risk, inalienability, illiquidity, and
lack of marketability, is proper here. Lastly, we note that for
purposes of disposing of the legal issues raised by this
proceeding, the parties have stipulated that if the Court
determines departure from the annuity tables is warranted, the
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