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of the same shares sold later in an IPO. The study concluded
that the sales prices in the nonpublic markets were 40 to 45
percent less than sales prices in the IPO's. Thus, Gasiorowski
concluded that the estimated marketable minority value, which he
implicitly assumes is equal to an IPO value, should be reduced by
45 percent to reflect the nonpublic market value of the shares.
We reject this conclusion for the following reasons.
Petitioner offered no evidence that the value of the shares
was affected by any change in the market conditions, the
constraints of the economy, or the financial condition of Savings
between the date of decedent's arm's-length sale of 1,111 shares
for $307 per share in the nonpublic market and the valuation date
1 month later. Consequently, if we apply the conclusions of the
IPO study to the case at hand, we find that it is more likely
that $307 is 40 to 45 percent less, rather than more, than the
price at which the same shares would sell in an IPO.
Furthermore, Gasiorowski disregards the fact that the actual
sales value of the shares is nearly identical to his estimated
marketable minority value. The near identity of values indicates
that the marketability of the Savings shares in the nonpublic
market is essentially equal to that of a minority interest in the
public market, in which case no discount for marketability is
required for a minority interest in Savings.
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