Estate of Adler, et al. v. Comr., T.C. Memo. 2011-28

(1,100 acre tract included in decedent's gross estate not entitled to fractional interest discounts; during life, decedent had transferred one-fifth remainder interest to each of his five children, but retained a life estate in the property; decedent failed to sell the remainder interests for their actuarial fair market value; full FMV of property included in decedent's estate at death - $6,390,000).