Estate of William J. Desmond, Deceased, Donn Kemble, Executor - Page 18




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               The income method assumed the continuation of Deft's present           
          policies and did not account for a change in control.  This                 
          method therefore produced an unadjusted value based on a minority           
          interest.  Id. at 195.  Thus, it would be proper to apply a                 
          control premium to the unadjusted value under this method.  Id.             
               The market method is based on comparisons with publicly                
          traded stocks.  This method produces an unadjusted value which              
          represents the value of a minority interest, and it generally               
          would be proper to apply a control premium to the unadjusted                
          value under this method.  Id. at 162.                                       
               HML determined that a 25-percent control premium was                   
          appropriate under the market method.  We find HML's determination           
          reasonable, and we conclude that a control premium of 25 percent            
          is appropriate.  We shall apply this premium to the unadjusted              
          value we determined under the income method.6                               
                    4.  Conclusion                                                    
               Utilizing the income method and the market method, we find             
          the fair market value of decedent's interest in Deft on the                 
          alternate valuation date was:                                               








               6  HML already included the control premium in its                     
          unadjusted value determined under the market method; therefore,             
          we shall not apply a separate control premium to the unadjusted             
          value under that method.                                                    

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