- 55 - supra. Considering the unsatisfactory record before us, we conclude that the estate has shown entitlement to a fractional interest discount no greater than that which would reduce the values of Parcels 2 and 3 to the amounts reported on the return. The evidence of fractional interest discounts supplied by Mr. Reyman is too fraught with infirmities to constitute cogent proof that the reported values are erroneous. See Estate of Pillsbury v. Commissioner, supra. We accordingly conclude on this record that the values of Parcels 2 and 3 are subject to fractional interest discounts of approximately 15 percent, which reduces those values to the amounts reported on the return. We so hold. IV. $30,000 Gift As part of the negotiations that produced the 1995 FSA, it was agreed that the conservator would reimburse various Amlie family members for a portion of the legal expenses each incurred in connection with the proceedings concerning approval of the 1994 Agreement. As ordered by the district court approving the 1995 FSA, the conservator paid $30,000 to Rod to effectuate the terms of the 1995 FSA. Respondent determined that the conservator's payment was a gift made by decedent prior to her death.34 The estate disagrees, contending that the payment was 34 The conservator was also required to pay $500 each to Rosemary Ahlerich and Susan Wendel in partial reimbursement for legal expenses they incurred in connection with the proceedings for approval of the 1994 Agreement. Respondent, considering (continued...)Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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