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discount for a minority interest in Savings; therefore, the 45-
percent discount that Gasiorowski would apply to the estimated
value must be for only the lack of marketability of petitioner's
block of shares.
We find Gasiorowski's reliance on the restricted stock
studies for the size of the discount factor to be misplaced,
since the studies analyzed only restricted stock that had a
holding period of 2 years. The Savings shares were not
restricted either by law or by agreement. The fact that Savings
maintained a waiting list of willing buyers is evidence that the
stock's history of low trading volume is due to the shareholder's
preference to hold Savings shares for investment, rather than for
sale. As the investment time horizon of an investor in Savings
stock evidently is long term, we do not believe that
marketability concerns rise to the same level as a security with
a short-term holding period like a restricted stock. See Furman
v. Commissioner, T.C. Memo. 1998-157. Therefore, we find no
persuasive evidence in the record to support reliance on the
restricted stock studies in determining an appropriate
marketability discount.
Furthermore, we do not find Gasiorowski's conclusions with
respect to the IPO study persuasive. The IPO study compared the
sales prices of relatively small amounts of a corporation's
shares before they were offered to the public to the sales prices
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