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for the property, a partnership agreement, and a partial sale
which took place 3 years after the valuation date. Because the
offers were not completed commercial transactions and are flawed
as comparables, we rely primarily on a comparable analysis to
determine that the fair market value of the property at the
valuation date was $5,463,666.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of his death,
Michel Dunia (decedent) was domiciled in Los Angeles, California.
The executors resided in Los Angeles, California, at the time the
petition was filed.
Decedent died on June 22, 1996. On the date of death,
decedent owned 100 percent of the Michel Dunia Trust (the trust).
The trust owned the property at issue (the Victorville property),
which is legally described as 92.91 net acres (4,047,160 square
feet) of undeveloped land located at the Southwest Quadrant of
Bear Valley Road and Amargosa Road, Victorville, San Bernardino
County, California. After his death, decedent’s children, Renee
Dunia Hawley and Michel Dunia, Jr., were appointed the executors
of the estate and co-trustees of the trust (Ms. Hawley and Mr.
Dunia are sometimes hereinafter referred to as the trustees).
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