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estimated $120 million valuation of the Partnership Properties.
Because respondent's expert does not make any adjustments for
date of sale, location, condition, or size of the property, we do
not find his comparable sales analysis persuasive.
After considering all relevant facts and circumstances and
taking into account the expert opinions submitted to us, we
conclude that the date-of-death value of the underlying
Partnership Properties equaled $100 million, as reflected in
petitioner's expert witness report. This value, as of
December 31, 1989, is particularly supported by the economic
recession that New York City was experiencing, by the weak
commercial real estate market, and by CUNY's notification of the
likely termination in the early 1990's of a major portion of its
lease of office space in the Partnership Properties.
As indicated above, with respect to discounts for minority
interest and lack of marketability, petitioner's expert applies a
combined discount rate of 67.5 percent to his $614,781 per-unit
liquidation value for each ownership unit in the FC Partnership,
relying primarily on the July 1989 sale to Mr. Silver of a
fractional 62.5-percent interest in a single ownership unit in
the FC Partnership.
Respondent's expert relies on various market studies that
indicate a discount of approximately 19 percent for minority
interests. Respondent's expert believes that an owner of a unit
in the FC Partnership could effectively participate in management
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