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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...)
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