-24- used in Estate of Feldmar to convert Crossroads' weighted average earnings in that the Court in Estate of Feldmar applied the capitalization rate to posttax earnings and Wise applied it to pretax earnings. The corporation in Estate of Feldmar sold life insurance, individual and family accident and health insurance, vehicle warranty/service contracts, and collateral protection services; Crossroads sells only workers' compensation reinsurance. Unlike life insurance, workers' compensation reinsurance is long-tail insurance because of the length of time before a reinsurer's obligations mature. See S. Rept. 99-313, at 502 (1986), 1986-3 C.B. (Vol. 3) 502. This makes the size of the reinsurer's reserve much more important because the reinsurer's liability can extend for longer periods. Id. D. Discount Petitioner argues that we should apply a 35-percent discount for minority interest and lack of marketability to Gallagher's estimate of the value of Crossroads' stock (zero for January 1, 1992 and $331 per share for January 1, 1993), and thus contends that the stock was worth zero on January 1, 1992, and $215 per share on January 1, 1993. Respondent agrees that petitioner is entitled to lack of marketability and minority interest discounts. Respondent applied a 35-percent discount to the fair market value ofPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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