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However, before reaching a definite conclusion of the
stock's value, Gasiorowski interviewed several experts who value
closely held bank stocks. From his discussions with these
experts, Gasiorowski concluded that if a block of stock of the
size held by petitioner were publicly traded, it most likely
would trade at 55 to 60 percent of book value. Applying this
discount to the October 31, 1991, book value of the Savings stock
suggested a public market value of $156 to $170 per share. Thus,
Gasiorowski concluded that the date-of-death fair market value of
petitioner's shares was $170 per share. We do not find
petitioner's opinion persuasive.
Discounts for a Minority Interest and Lack of Marketability
A minority interest discount reflects the minority
shareholder's inability to compel either the payment of dividends
or liquidation in order to realize a pro rata share of a
corporation's net earnings or net asset value. A lack of
marketability discount reflects the fact that there is no ready
market for shares in a closely held corporation. Thus, discounts
for a minority interest and for lack of marketability are
conceptually distinct, and the appropriate percentage rate of
each of them is a question of fact. See Estate of Newhouse v.
Commissioner, 94 T.C. at 249. Gasiorowski concluded that if the
stock were publicly traded, the value of a minority interest
would be $310 per share. This estimated value reflects the
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