Maude G. Furman, Donor, Deceased, and Estate of Maude G. Furman, Deceased, Robert G. Furman, Executor - Page 45

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          resulting uncertainties; see e.g., Dockery v. Commissioner, T.C.            
          Memo. 1998-114 (40-percent combined minority and marketability              
          discount); Estate of Mitchell v. Commissioner, T.C. Memo. 1997-             
          461 (35-percent combined minority and marketability discount);              
          LeFrak v. Commissioner, T.C. Memo. 1993-526 (30-percent combined            
          discount); Estate of Gallo v. Commissioner, T.C. Memo. 1985-363             
          (36-percent marketability discount, with references to minority             
          issues).  We reject both respondent's combined discount of 17               
          percent and petitioners' separate 30-percent minority discount              
          and 35-percent marketability discount and conclude that a 40-               
          percent combined minority and marketability discount is                     
          appropriate in this case.                                                   
                    d.   Key-Person Discount                                          
               Where a corporation is substantially dependent upon the                
          services of one person, and where that person would no longer be            
          able to perform services for the corporation by reason of death             
          or incapacity, an investor would expect some form of discount               
          below fair market value when purchasing stock in the corporation            
          to compensate for the loss of that key employee.  See Estate of             
          Huntsman v. Commissioner, 66 T.C. 861 (1976); Estate of Mitchell            
          v. Commissioner, supra; Estate of Feldmar v. Commissioner, T.C.             
          Memo. 1988-429; Estate of Yeager v. Commissioner, T.C. Memo.                
          1986-448.  Although FIC could have purchased key-person life                
          insurance on Robert's life, a minority shareholder could not                
          compel FIC to purchase such insurance, and FIC had no such                  




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