Albert M. Graham and Martha A. Graham - Page 26

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               2.   Value of a 22.375-percent Interest in the Property of             
                    the Anis Partnership                                              
               We next decide the fair market value of a 22.375-percent               
          interest in the property of the Anis partnership.                           
                    a. Positions of the Parties                                       
               Respondent contends that, on May 30, 1995, the fair market             
          value of petitioner’s 22.375-percent interest in the Anis                   
          partnership was $112,255.84, consisting of $47,443.51 cash and              
          interest in two parcels of real property having a fair market               
          value of $64,812.33, calculated as follows:                                 
               $425,637 (� interest in the Riverside property)*                       
               $ 20,000 (1/4 interest in the Kansas farm)*                            
          $445,637                                                                    
               x 22.375%  (Graham’s partnership interest)                             
               $99,711.28                                                             
               x 65%      (35% minority/marketability discount)                       
               $64,812.33                                                             
          * per partnership’s balance sheet                                           
               Petitioners contend that the value of a 22.375-percent                 
          interest in the cash and property received by the Anis                      
          partnership in 1995 was $70,587, calculated as follows: (1)                 
          $33,383 for a cash payment to the partnership (cash of $229,538             
          received by the partnership times 22.375 percent = $51,359,                 
          discounted 35 percent = $33,383), plus (2) $35,750 for a one-half           
          interest in the Riverside property ($250,000 fair market value              
          (50 percent interest received by the partnership) times 22                  
          percent = $55,000, discounted 35 percent = $35,750), plus                   
          (3) $1,454 for a one-fourth interest in the Kansas farm ($10,000            





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