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acquisition transactions and REIT’s to support the chosen
discount, but it did not cite specific studies, describe the
studies’ assumptions and findings, or analyze the control
features of the True oil subject interests. We therefore
disregard the final Lax report’s proposed minority discount.
We also disagree with respondent’s argument that the 38.47-
percent interest Dave True owned at death would be combined with
any other single ownership block to control True Oil so that a
minority discount is unjustifiable. In determining whether a
minority discount applies, we do not assume that the hypothetical
buyer is a member of decedent’s family. See Propstra v. United
States, 680 F.2d 1248, 1251-1252 (9th Cir. 1982); Estate of Hall
v. Commissioner, supra; Minahan v. Commissioner, 88 T.C. 492, 499
(1987). Here, we assume that the buyer is an unrelated party,
but we are free to recognize Jean True and the True sons as the
other general partners as of Dave True’s death. See Estate of
Davis v. Commissioner, 110 T.C. 530, 559 (1998). Given these
assumptions, we find it unlikely that a member of Dave True’s
family would join forces with an unrelated purchaser to gain
voting control over True Oil. See id. In addition, the concept
of voting control does not apply to True Oil, a general
partnership that is jointly managed by all of its owners. Cf.
Estate of Winkler v. Commissioner, T.C. Memo. 1989-231
(distinguishing voting from nonvoting stock for valuation
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