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On June 9, 1997, decedent Ida Abraham died in Boston,
Massachusetts. On the date of decedent’s death, the fair market
value of the Tyngsboro property was $2.2 million, and the fair
market value of the Walpole and Smithfield properties was
$830,000. After decedent’s death, Ms. Cawley received a
$93,078.62 distribution from the DAC FLP, and Ms. Slater received
a $120,869.42 distribution from the DAS FLP.
Mr. Lipof determined the values of the FLPs for purposes of
valuing the decedent’s taxable estate, as of the date of death.
In a letter dated January 20, 1998, Mr. Lipof appraised the value
of the RMA FLP at $830,000 by looking at the value of the
underlying properties that FLP held.19 Mr. Lipof valued
decedent’s supposed 45-percent interest at a “gross book value”
before discounts of $373,500. He then stated that a 30- to 40-
percent discount of the “gross book value” would be appropriate,
estimating the market value of decedent’s interest to be
$242,750. Under a similar methodology, Mr. Lipof determined that
the Tyngsboro property had a value of $2.2 million. Mr. Lipof
explained that at the time of decedent’s death, she owned 33.3
percent in the DAS and DAC FLPs, with a value before discounts of
$733,333. Applying the same 30- to 40-percent discount, Mr.
Lipof opined that the market value of decedent’s interest in the
19Mr. Lipof was a real estate consultant.
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