Estate of Helen A. Deputy, Deceased, William J. Deputy, Co-Executor - Page 29

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          not contemporaneous to the 1997 valuation year because they were            
          gathered in the mid to late 1960s and early 1970s.                          
               Mr. Dorman also provided a brief discussion on minority                
          discounts which concluded with the statement that an analysis of            
          “Tax Court cases between 1950 and 1982 * * * disclosed a median             
          25-percent minority discount.”  Following this general discussion           
          of marketability and minority discounts, Mr. Dorman, in an                  
          attempt to summarize his commentary, referenced a study by                  
          Professor Steven E. Bolten which concluded that on the basis of             
          other studies in existence as of 1984, average discounts for                
          marketability and minority were 39.86 percent and 29.37 percent,            
          respectively.                                                               
               Neither party’s expert attempted to persuade us to rely or             
          not to rely on the various studies he referenced.  Mr. Dorman’s             
          discount approach focuses more specifically on Godfrey’s unique             
          attributes and therefore provides a more direct approach to                 
          evaluate the interest in Godfrey.  Additionally, we do not accept           
          respondent’s expert’s position that no minority discount should             
          apply where value is estimated by means of an income approach.              
          Although Mr. Dorman’s approach is more subject specific, no                 
          foundation or background is provided to support the indexing in             
          each category in the matrix.  In that regard, the matrix was                
          created by Mr. Dorman’s company and is obviously subjective.                
          Finally, as explained below, we do not agree with parts of Mr.              






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