- 34 - time. For this reason, we conclude that the lower end of Mr. Ruppert's scale of 2.5 to 3 is an appropriate multiplier to be applied to the net sales of SOAI for 1981 to obtain the fair market value of the assets of SOAI on January 25, 1982. We, therefore, hold that an asset sale of SOAI on January 25, 1982, should be at a multiplier of 2.5 applied to SOAI's net sales for the year 1981. The fair market value of the SOAI stock can be ascertained from this figure by making the adjustments made by respondent's witness, Mr. Loe. The parties stipulated that the value of the SOAI stock transferred by decedent in 1980 and 1981 is the same as the value as of January 25, 1982, subject to any discount that the Court might determine applicable for marketability or minority interest due to the smaller number of shares transferred. There is not very much in the record with respect to an appropriate amount of either a marketability discount or minority interest discount. Respondent, to some extent, seems to contend that the 1980 and 1981 transfers were part of the same overall plan as the 1982 transfer. However, these transfers appear more to be a continuation of small gifts made by decedent to his family in prior years than part of the plan to give his son John the majority interest in SOAI in 1982. There is very little evidence in the record as to an appropriate amount for a marketability discount or a minority interest discount. Obviously, if all of the assets were sold, the minority shares would have the same perPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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