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motel valuation--provides no meaningful assistance in measuring
any such impairment of value. Nor does the record otherwise
provide a reliable basis for estimating any such impairment of
value.7
Moreover, if we were to assume, for sake of argument, that
the gross estate, as determined by respondent (and as reported on
decedent’s estate tax return), should be adjusted downward to
reflect some impairment to the value of decedent’s C&L Bailey
stock resulting from the divided ownership of parcel 2, it would
follow (as petitioner concedes) that decedent’s gross estate
should be correspondingly increased to reflect decedent’s
inadvertently omitted individual ownership interest in parcel 2.
Petitioner has not shown that the net result of these correlative
adjustments would be to the estate’s advantage. To state the
problem more precisely, petitioner has not shown that ignoring
any such title-related impairment to the value of the California
motel resulted in an overstatement of decedent’s gross estate
greater than the understatement of the gross estate that resulted
from the omission of decedent’s individual ownership interest in
7 As previously discussed, Schwartz deviated from the
Ohrmund report in making a $193,000 downward adjustment to
reflect the divided ownership of parcel 2. Schwartz, however,
offered no explanation or support for this downward adjustment.
Consequently, his report is of little assistance in measuring the
effect of the “clouded title” of parcel 2 on the value of the
California motel. Petitioner has not argued that we should rely
on Schwartz’s conclusion in this regard.
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