- 12 - Because the record does not show that a marketability discount applies to the stipulated value of the Decedent’s CGT shares, we hold that no discount for marketability is allowable.7 In so holding, we have considered all arguments made by petitioner, and, to the extent not discussed above, have found them to be without merit. To reflect the foregoing, Decision will be entered under Rule 155. 7 Respondent argues that the fact that the Decedent controlled CGT means that a control premium exists to the extent of any marketability discount. Based on our holding, we need not, and do not, address this argument.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011