Charles T. McCord, Jr. and Mary S. McCord, Donors - Page 45

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                    b.  Petitioners’ Expert                                           
               Petitioners offered William H. Frazier (Mr. Frazier) as an             
          expert witness to testify concerning the valuation of the gifted            
          interest.  Mr. Frazier is a principal of Howard Frazier Barker              
          Elliott, Inc. (HFBE), a Houston-based valuation and consulting              
          firm.  He is a senior member of the American Society of                     
          Appraisers and has been involved in valuation and general                   
          investment banking activities since 1975.  The Court accepted Mr.           
          Frazier as an expert in the valuation of closely held entities              
          and received written reports of HFBE into evidence as Mr.                   
          Frazier’s direct and rebuttal testimony, respectively.                      
               In his direct testimony, Mr. Frazier concludes that, based             
          on a 22-percent minority interest discount and a 35-percent                 
          marketability discount, the fair market value of a 1-percent                
          assignee interest in MIL on the valuation date was $89,505.                 
          Based on that figure, Mr. Frazier further concludes that the fair           
          market value of each petitioner’s one-half share of the gifted              
          interest on the valuation date was $3,684,634 (a figure that, due           
          to rounding, is slightly lower than the value reported on the               
          Forms 709).11                                                               


               11  Mr. Frazier asserts that a 41.167-percent assignee                 
          interest in MIL (i.e., one-half of the gifted interest) has no              
          more proportionate value than a 1-percent assignee interest                 
          therein, and respondent’s expert does not dispute that assertion.           







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