- 74 -                                         
          upon the basis for Mr. Marsh’s ranges nor provided any exegesis             
          for his derivation therefrom of a 33.33-percent discount for the            
          Marsh note.                                                                 
               Faced with this limited record, we observe that both sides’            
          treatments of discount ranges leave something to be desired in              
          terms of support and explanation.  Nonetheless, we again are                
          satisfied that Mr. Thomson has submitted the more convincing                
          position.  We know that he is a licensed real estate broker and             
          appraiser, and his testimony tied the selected range to data                
          regularly received from professionals in the real estate                    
          brokerage field.  In contrast, we reiterate that Mr. Marsh’s                
          alleged expertise in this area is not established by the record.            
          We additionally repeat our concern about the complete absence of            
          information as to the underpinnings for his views.  We therefore            
          accept Mr. Thomson’s 5- to 15-percent range.                                
               Within the above-stated range, however, we seek a discount             
          reflective of one factor tending to decrease and two tending to             
          increase the applicable figure, rather than an even split of                
          factors.  Accordingly, we conclude that 12 percent, or two-thirds           
          of the spread from 5 to 15 percent (rounded), is an appropriate             
          discount.  The fair market value of the Marsh note is thus held             
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