Estate of Paul Mitchell, Deceased - Page 17




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          provides a marketable, minority ownership indication of value.  Id.         
          at 304.  Under this method, a discount from the listed value is             
          typically warranted in order to reflect the lack of marketability           
          of the unlisted stock.  Mandelbaum v. Commissioner, T.C. Memo.              
          1995-255, affd. without published opinion 91 F.3d 124 (3d Cir.              
          1996).  If the stock to be valued by the market approach represents         
          a minority interest, no discount for the lack of control is applied         
          because the method reflects a minority interest.  If, on the other          
          hand, the stock represents a control interest, a control premium is         
          warranted in order to reflect the increased value over the minority         
          value determined under the market valuation method.  Estate of              
          Desmond v. Commissioner, T.C. Memo. 1999-76.                                
               A discounted economic income approach can produce either a             
          control value or a minority value, depending on the assumptions             
          used in determining the economic income projections and the                 
          discount rate.  Where the method used values the stock as if it             
          were a controlling interest, no control premium is necessary                
          because the control aspect has already been accounted for within            
          the unadjusted value.  Pratt, supra at 303-306.  “The most common           
          example of economic income projections that would lead to a                 
          minority or control value is whether or not owners’ compensation is         
          adjusted to reflect value of services rendered.”  Id. at 304.               










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