rofessionals, no penalties were added. Somewhere, Edward is smiling. W T.C. Memo. 2015-237 (December 9, 2015) * Mr. Hall is a Managing Director of FMV Opinions. Inc., a national valuation and investment banking firm with offices in New York, San Francisco, Irvine, and Dallas. Mr. Hall heads up FMV's estate a

ne, and Dallas. Mr. Hall heads up FMV's estate and gift tax valuation practice. He may be reached at Walla fmv.com. Additional information regarding FMV Opinions. Inc. can be accessed at www.fmv.com. 121 The Fifth Circuit, while never addressing this issue directly, clearly considered the co-tenant agreement in