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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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