Maude G. Furman, Donor, Deceased, and Estate of Maude G. Furman, Deceased, Robert G. Furman, Executor - Page 43

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          publicly traded investment companies that specialized in                    
          restricted securities.  The study found mean marketability                  
          discounts of 33 percent after analyzing 89 restricted stock                 
          investments by the four investment companies.  The second study,            
          Moroney, "Most Courts Overvalue Closely Held Stocks", 51 Taxes              
          144 (Mar. 1973), is based on 10 registered investment companies             
          that held a total of 146 blocks of restricted equity securities.            
          The Moroney study found an average discount on the restricted               
          stock transactions of 35.6 percent.  The third study, Maher,                
          "Discounts for Lack of Marketability for Closely Held Business              
          Interests", 54 Taxes 562 (Sept. 1976), is based on reports filed            
          with the Securities and Exchange Commission by four mutual fund             
          companies reporting their restricted stock transactions.  The               
          Maher study found a mean discount of 34.73 percent.  The final              
          study cited was an IPO study, Emory, "The Value of Marketability            
          as Illustrated in Initial Public Offerings of Common Stock                  
          February 1992 through July 1993", Bus. Valuation Rev. 3 (Mar.               
          1994).  The Emory study found an average marketability discount             
          of 46 percent after comparing the share price in private                    
          transactions that occurred within 5 months of an IPO by the same            
          corporation.  We find petitioners’ reliance on the restricted               
          stock studies to be misplaced, since those studies analyzed only            
          restricted stock that had a holding period of 2 years.  Inasmuch            
          as we expect the investment time horizon of an investor in the              
          stock of a closely held corporation like FIC to be long term, we            




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