- 19 - should be applied in valuing decedent's 50-percent stock interest in B&W Longview. Although Mr. Harrell specified that he would apply a 10-percent discount, Mr. Bernstein did not specify how much of the 35-percent combined discount that he applied was attributable to the fact that decedent did not own a controlling stock interest in B&W Longview on the valuation date. On brief, petitioner, who has the burden of proof, does not insist that a minority discount in excess of 10 percent be applied in this case. Respondent contends, and petitioner disputes, that, because the precedent transactions on which both experts, inter alia, relied involved stock for which there was no ready market, the respective prices paid for the stock sold in those transactions reflected some lack-of-marketability discount. While we gener- ally agree with respondent, it is significant that the stock interests acquired in the precedent transactions were different from decedent's 50-percent stock interest in B&W Longview in that (1) the respective purchasers in the transactions involving (a) B&W El Paso and (b) B&W Brownsville, B&W Harlingen, B&W Mission, B&W Austin, and B&W Finance acquired 100 percent of the stock of each of those corporations; and (2) although decedent purchased only 50 percent of the stock of TA&T Finance in the Young transaction, after that purchase, decedent owned 100 percent of the stock of that corporation. On the record beforePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011