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the fair market value at that time of all the members’ interests in the partnership or beneficiaries’ interests in the trust, as the case may be, and
the fair market value at that time of all the members’ interests in the partnership or beneficiaries’ interests in the trust, as the case may be, and
the fair market value at that time of all the members’ interests in the partnership or beneficiaries’ interests in the trust, as the case may be, and