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that fractional interest discounts are warranted because of
problems of control, lack of marketability, unavailability of
financing, and costs of partition relating to partial undivided
ownership interests. This Court has found fractional interest
discounts to be appropriate where supported by the evidence.
See, e.g., Estate of Campanari v. Commissioner, 5 T.C. 488, 492
(1945); Estate of Henry v. Commissioner, 4 T.C. 423, 447 (1944),
affd. 161 F.2d 574 (3d Cir. 1947); Estate of Baird v.
Commissioner, T.C. Memo. 2001-258; Estate of Busch v.
Commissioner, T.C. Memo. 2000-3; Estate of Pillsbury v.
Commissioner, T.C. Memo. 1992-425.
In his first report Mr. Reyman noted that, while fractional
interest discounts for Parcels 2 and 3 were appropriate, he
lacked adequate information from which he could determine what
rate of discount to apply. Mr. Reyman subsequently submitted a
second report in which he identified certain fractional interest
data he had found which formed a basis for an opinion regarding
fractional interest discounts for Parcels 2 and 3. Mr. Reyman
acknowledged that his data was remote as to time (consisting of
sales in 1996-1998) and location (being from eastern rather than
northwest Iowa). He nonetheless believed that the data supported
a substantial discount "to compensate potential buyers for the
lack of control, limited marketability, and low financing
potential characteristic of such interests", and concluded that a
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