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             Second, the Court recognized Steven Jon Shanker, C.P.A. (Mr.             
        Shanker), as an expert on the market absorption discount.  The estate         
        retained the accounting firm of Coopers & Lybrand, L.L.P., to                 
        ascertain the rate of the market absorption discount that applied to          
        each parcel of the subject property, and Mr. Shanker, a partner in            
        that firm who specializes in valuation, was assigned the job.                 
        Mr. Shanker has a Bachelor of Arts in Accounting and a Master of              
        Business Administration in Taxation, and he is a senior member in the         
        business valuation area of the American Society of Appraisers.                
        He has never appraised real estate or applied a market absorption             
        discount to real estate (before the instant case), but he has valued          
        many entities whose assets included real estate and has been involved         
        in numerous blockage situations related to the valuation of stock.            
        Many (if not all) of the entities valued by Mr. Shanker were his              
        clients.                                                                      
             Mr. Shanker concluded that a 20-percent market absorption                
        discount applied to each parcel of the subject property.  In so               
        doing, he reviewed the appraisers' appraisals and financial,                  
        economic, and census data on Genesee County real estate.  He                  
        analogized an underwriter's role in disposing of stock to the role of         
        the Resolution Trust Corporation (RTC) in disposing of real estate;           
        Congress formed the RTC to dispose of real estate held by insolvent           
        savings and loan institutions (S&L's).  He concluded that "It would           
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