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for minority interest and 26-percent discount for lack of
marketability).
Applying this 45-percent combined discount to the per-unit
partnership liquidation value that we have found provides a date-
of-death fair market value of $338,130 for decedent's ownership
unit in the FC Partnership.
The schedule below reflects our conclusions with regard to
each element of the relevant computation of fair market value:
Valuation of Partnership
Properties Before Discounts:
Estimated Gross Annual Lease Income $15,082,200
Contingency Loss Reserve 5%
Operating Expenses $6,650,193
Estimated Annual Lease Income $8,432,007
Capitalization Rate 8.5%
FMV of Partnership Properties $100,000,000
Less Partnership Liabilities $41,595,787
FC Partnership Net Liquidation Value $58,404,213
Per-Unit Liquidation Value $614,781
Discounts For:
Minority Interest 19%
Lack of Marketability 26%
Combined Discount 45%
FMV of Decedent's Ownership Unit: $338,130
To reflect the foregoing,
Decision will be entered
under Rule 155.
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