Co-tenancy interests are common in the world of gift and estate tax. Consequently, the valuation of such interests is a recurring assignment for business valuation professionals and a frequent issue in estate and gift tax audits. Numerous articles have been published on the valuation of undivided interests,1 and, as a result, three accepted methods have arisen:  (1) empirical co-tenancy discount data; (2) income approach using a partition assumption; and (3) limited ...

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