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results that Mr. Bernstein reached under his modified market
multiple method are reliable, and we shall not give any weight to
those results in determining the fair market value on the valua-
tion date of the stock interest in question.5 Consequently, we
shall ignore Mr. Bernstein's opinion that, under his modified
market multiple method and before considering any discounts that
he believed are warranted because of the lack of control and the
lack of marketability inherent in decedent's 50-percent stock
interest in B&W Longview on the valuation date, its value was
$660,050.
Although we shall not rely on Mr. Bernstein's modified
market multiple method, for the sake of completeness we shall
describe what Mr. Bernstein did with the results that he derived
under that method. After having arrived at the respective values
of the stock interest in question under his modified market
multiple approach and the transaction method and after having
determined that each such value should be accorded equal weight
in ascertaining the fair market value of that interest, Mr.
Bernstein calculated the mean of those two values to be $930,425
(mean value). He applied a 35-percent combined minority and
5 There are additional reasons why we are not convinced that the
results under Mr. Bernstein's modified market multiple method are
reliable. For example, Mr. Bernstein did not adequately explain,
and has not convinced us, that his determinations of the market
multiples for the guideline companies that he selected are
proper.
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