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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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