- 39 - Valuation by Reference to the Partnership Units The partnership units were publicly traded on the Pacific Stock Exchange. There were approximately 1.2 million partnership units outstanding. During the first 20 days following commencement of "when issued" trading, the aggregate trading volume was 116,892 units, or 9.7 percent of the number of units outstanding, and the weighted average trading price of the units was approximately $11.50 per unit. Petitioner argues that the value of the Washington assets held by the Partnership must be determined by reference to the partnership unit prices set by the market. Thus, according to petitioner, the Partnership's assets had an aggregate fair market value on December 20, 1985, of approximately $41.5 million based on the sum of (1) the aggregate public trading price of the units (i.e., 1.2 million units x $11.50 per unit, or $13.8 million) and (2) the initial indebtedness of the Partnership ($27.7 million). Furthermore, petitioner argues that the unit price does not represent a discount from the liquidation value of the partnership, because with a publicly traded company, there is no difference between the aggregate trading value of the units and the amount produced by subtracting the entity's liabilities from the fair market value of its individual assets. To support its position, petitioner introduced the reports and testimony of two expert witnesses, Professor Michael Bradley,Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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