Estate of Pearl I. Amlie, Deceased, Rodney B. Amlie, Executor - Page 52

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          the comparables for Parcels 1, 2, and 3, and the elimination of             
          this adjustment raises the indicated value by $25 per acre, or              
          $3,396 for Parcel 1.  We also conclude that Mr. Reyman should               
          have utilized the average of the adjusted values of his six                 
          comparables for Parcel 1, rather than adopting one comparable.  A           
          modification to employ the average raises the indicated value for           
          Parcel 1 by $75 per acre, or $10,187.  We accordingly find that             
          the estate has shown respondent's determination to be incorrect,            
          and that the value of Parcel 1 on the valuation date was                    
          $295,383.                                                                   
               Mr. Reyman estimated that decedent's seven-twelfths interest           
          in Parcel 2, without regard to any discount for a fractional                
          interest, had a value of $195,300 on the valuation date.  He                
          further estimated that decedent's one-half interest in Parcel 3,            
          without any fractional interest discount, had a value of $185,000           
          on the valuation date.  After removing the unjustified $150                 
          downward adjustment to one comparable, the value of Parcel 2                
          increases $2,325 (7/12 of $25 per acre) to $197,625, and the                
          value of Parcel 3 increases $2,917 (1/2 of $25 per acre) to                 
          $187,917.  We consider the impact of any fractional interest                
          discounts below.                                                            
          Impact of Fractional Interests                                              
               Since decedent held only seven-twelfths and one-half                   
          interests in Parcels 2 and 3, respectively, the estate argues               






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