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of 24 percent is appropriate in determining the fair market value
of each limited partnership interest that petitioner transferred
in 1996.
E. Conclusion
We conclude that for April 19, 1996, the fair market value
of the 69.4815368-percent gifted partnership interests is
$1,417,006, computed as follows:
Total NAV as of 4/19/96 $3,156,882
1 percent of NAV 31,569
Less: 15-percent minority interest
discount (4,735)
26,834
Less: 24-percent marketability discount (6,440)
FMV of 1-percent interest 20,394
FMV of 69.4815368-percent interests 1,417,006
We conclude that for July 2, 1996, the fair market value of
the 29.2184632-percent gifted partnership interest is $611,455,
computed as follows:
Total NAV as of 7/2/96 $3,239,531
1 percent of NAV 32,395
Less: 15-percent minority interest
discount (4,859)
27,536
Less: 24-percent marketability discount (6,609)
FMV of 1-percent interest 20,927
FMV of 29.2184632-percent interest 611,455
To reflect the foregoing,
Decision will be entered
under Rule 155.
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