Estate of Joseph R. Cloutier, Joseph A. Cloutier, Fiduciary - Page 9

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          typically see with respect to an expert’s opinion of valuation,             
          Mr. Alerding’s report is three pages long and consists mainly of            
          bald assertions that a 25-percent marketability discount is                 
          warranted.  His report contains no meaningful discussion of any             
          of the factors of valuation; it does not reflect a review of                
          basic information necessary to render an opinion on valuation;              
          and it shows undue reliance on appraisals performed by third                
          parties.  As a point of fact, one of the appraisals on which                
          Mr. Alerding purported to rely was merely a draft of an                     
          appraisal, and Mr. Alerding never spoke to the author concerning            
          the author’s completion of that draft or about any of the                   
          information contained therein.                                              
               Mr. Alerding also relied on studies of property that was not           
          comparable to the subject property in order to form a “benchmark”           
          on which to base his conclusion concerning the amount of a                  
          marketability discount.  He failed to evaluate properly whether             
          the Decedent's 100-percent interest in CGT merited a premium for            
          control, or whether such a premium (if one existed) would                   
          neutralize his proffered marketability discount.4  He focused               


          4 The Court has often determined a control premium in the                   
          case of a majority interest.  See, e.g., Estate of Trenchard v.             
          Commissioner, T.C. Memo. 1995-121, and the cases cited therein.             
          A control premium reflects a shareholder's ability to control a             
          corporation through his or her dictation of its policies,                   
          procedures, or operations.  Estate of Chenoweth v. Commissioner,            
                                                             (continued...)           






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