-25- 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 dividendsPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011