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of certainty and administrative convenience in ascertaining
property values and prove accurate when applied in large numbers
of cases, although discrepancies inevitably arise in individual
cases.” Bank of Calif. v. United States, supra at 760. There is
also, in these cases specifically dealing with the standard for
departure, once again a salient absence of any consideration
regarding what rights the payee may have had to liquidate or
dispose of his or her interest. In fact, the income right at
issue in Estate of Christ v. Commissioner, 54 T.C. at 499, 542,
which was held subject to valuation under the tables of section
20.2031-7, Estate Tax Regs., was expressly made nonassignable.
The trust instrument provided:
The beneficiaries of this trust are hereby
restrained from selling, transferring, anticipating,
assigning, hypothecating or otherwise disposing of
their respective interests in the corpus of the said
trust, or any part thereof, and of their respective
interests in the income to be derived and to accrue
therefrom, or any part thereof, at any time before the
said corpus or the said income shall come into their
possession under the terms of said trust * * * [Id. at
499.]
Yet no deviation was permitted. See id. at 537, 542.
Moreover, it is noteworthy that other forms of annuity which
lack liquidity are expressly required by statutes and regulations
to be valued under the Commissioner’s prescribed tables. For
instance, in the context of a grantor-retained annuity trust,
section 2702(a)(2)(B) mandates valuation of a qualified retained
annuity interest under section 7520. Nonetheless, in order to
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