Louise B. Barnes, Donor, et al. - Page 25

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          D.   Discounts                                                              
               1.   Lack of Marketability                                             
               A discount for lack of marketability may apply to minority             
          interests in closely held corporations because there is no ready            
          market for those shares.  Estate of Andrews v. Commissioner, 79             
          T.C. at 953.  Respondent agrees that petitioners are entitled to            
          lack of marketability discounts for Home and Rock Hill stock.               
               Hawkins applied a 40-percent discount for lack of                      
          marketability to his estimate of the value ($360.93) of the Home            
          stock, and a 45-percent discount to the value ($337.87) of the              
          Rock Hill stock.  Hakala applied discounts of 25 percent for lack           
          of marketability to his estimate of the values of the Home ($518)           
          and Rock Hill ($546) stock.                                                 
               We agree with Hawkins' use of 40 and 45 percent discounts              
          because:  (a) The Barnes family has controlled Rock Hill for 80             
          years and the Helmly and Barnes families have controlled Home for           
          50 years; (b) both families intend to keep control of the                   
          companies; (c) the families have taken steps such as implementing           
          a voting trust, bringing the younger generations into the                   
          business, and buying insurance to avoid having to sell shares to            
          pay death taxes; (d) Home and Rock Hill pay much lower dividends            











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