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For convenience, the following chart (chart) shows the
respective positions of the experts6 and the parties on brief with
respect to the net asset value of ADDI&C on the valuation date and
the discounts or adjustments that each believes should be applied
to such value in order to arrive at the fair market value on that
date of each of the two 25-share blocks of ADDI&C stock in
question:7
6 The respective positions of the experts that are shown in the
chart reflect the agreement of the parties as to the fair market
value of each of ADDI&C's assets and the aggregate amount of its
liabilities as of the valuation date without taking into account
any type of discount or adjustment attributable to blockage
and/or SEC rule 144, lack of a controlling interest, lack of
marketability, or ADDI&C's built-in capital gains tax. However,
those positions do not reflect the agreement of the parties at
trial that the applicable minority discount should be 15 percent.
Despite that agreement, the respective dollar amounts of a 15-
percent minority discount urged on brief by petitioner and by
respondent differ. That is because of the differences between
them as to whether a blockage and/or SEC rule 144 discount and a
discount or adjustment attributable to ADDI&C's built-in capital
gains tax should be taken into account in arriving at ADDI&C's
net asset value on the valuation date.
7 All dollar amounts in the chart are rounded to the nearest
dollar.
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