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November 21, 1997. Absent any explanation from Mr. Dankoff as to
why it would be more appropriate for us to use his less
contemporaneous data, we utilize Mr. Burns’ price and NAV data in
our analysis.
e. Samples of Closed End Funds
i. Cash and Money Market Funds
Both Mr. Dankoff and Mr. Burns implicitly recognize the lack
of an appropriate sample of closed end funds from which to derive
a minority interest discount factor for the “cash and money
market funds” asset category. In his written report, Mr. Dankoff
assigns a 5-percent discount factor to that asset category and
notes that such figure is “[j]udgmentally determined recognizing
the relative risk/return tradeoff of this asset category vis a
vis U.S. Government Bond Funds”. Mr. Burns assigns a 2-percent
discount factor to the “cash and money market funds” asset
category, noting without further explanation that such figure is
an estimate. While we find neither expert persuasive on this
issue, we utilize a 2-percent discount factor in our analysis on
the grounds that (1) respondent has effectively conceded that a
discount factor of up to 2 percent would be appropriate, and (2)
petitioner has failed to carry his burden of persuading us that a
figure in excess of 2 percent would be appropriate.
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