In Adler, a decedent’s estate was not entitled to fractional interest discounts on the value of a ranch that the decedent had gifted to his five children years before his death. In 1965, a father executed a deed transferring an undivided one-fifth interest in his ranch to each of his five children. According to the terms of the deed, the father retained the right to possess, enjoy and receive income from the ranch during his life. The father also paid all expenses of the ranch and did not pay any rent. Upon the father’s death, his executors included the ranch in his gross estate, but applied fractional interest discounts to its value. The Tax Court disallowed the discount, finding that because the decedent retained a life estate, it was as though his ownership interest in the ranch was split upon his death. Therefore, fractional interest discounts were inappropriate because they would have allowed the estate to discount the ranch based on the number of beneficiaries of the property.