Estate of Lea K. Hillgren, Deceased, Mark Hillgren, Executor - Page 42

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               The value of the properties that were transferred to the               
          partnership is includable in decedent’s gross estate under                  
          section 2036(a).  The properties are included in the estate at              
          the fair market value on the date of decedent’s death, subject to           
          the effect of the BLA.                                                      
          Valuation of the Properties                                                 
               The parties have stipulated the undiscounted values of all             
          seven properties in which decedent had an interest.  Three of the           
          properties, Manzanita, Crescent Bay, and Railroad, are not                  
          subject to the BLA.  The three properties will therefore be                 
          included in the value of the estate at stipulated values of                 
          $2,261, $265,176, and $115,711, respectively.                               
               Property is included in the gross estate at its fair market            
          value, which is “the price at which the property would change               
          hands between a willing buyer and a willing seller, neither being           
          under any compulsion to buy or sell and both having reasonable              
          knowledge of relevant facts.”  Sec. 20.2031-1(b), Estate Tax                
          Regs.; Estate of Newhouse v. Commissioner, 94 T.C. 193, 217                 
          (1990).  The determination of fair market value is a question of            
          fact.  Estate of Newhouse v. Commissioner, supra at 217.  During            
          trial, we received reports and testimony from expert witnesses.             
          We evaluate the opinions of the experts based on the                        
          qualifications and reasoning of each expert and on all other                
          credible evidence in the record.  See Estate of Jones v.                    






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