- 274 -                                        
              Similarly, we reject Mr. Lax’s combined 60-percent minority             
          and marketability discount, because the studies that he relied on           
          dealt with transactions in limited partnership interests, not               
          general partnership interests.                                              
              We find respondent’s proposed 10-percent minority discounts             
          for interests transferred by Dave and Jean True to be                       
          unsubstantiated and insufficient.  Even though a general partner            
          in True Ranches may exert more control than a shareholder in a              
          public company or a limited partner in a publicly registered                
          partnership, he would not have unilateral control over business             
          decisions.  Further, we reject respondent’s swing vote argument             
          regarding Dave True’s 38.47-percent interest owned at death, for            
          the reasons stated in our analysis of True Oil.  See supra pp.              
          201-202.                                                                    
              Based on the record, we apply a 15-percent minority discount            
          to the controlling equity values computed by Mr. Kimball to                 
          arrive at a marketable minority value for True Ranches of                   
          $34,852,550 as of January 1, 1993, and $38,502,883 as of June 4,            
          and June 30, 1994.                                                          
                  2. Marketability Discounts                                          
                      a. Kimball Reports                                              
              Mr. Kimball treated the subject interests in True Ranches as            
          not being readily marketable for the same reasons described in              
          the True Oil section of this opinion.  See supra pp. 204-206.               
          Accordingly, Mr. Kimball applied 35-percent marketability                   
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