Estate of William J. Desmond, Deceased, Donn Kemble, Executor - Page 6




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          Mandelbaum v. Commissioner, supra; Estate of Trenchard v.                   
          Commissioner, supra.                                                        
               Some of the factors examined by courts in determining the              
          amount of an appropriate lack of marketability discount are:  (1)           
          The cost of a similar corporation's public and private stock; (2)           
          an analysis of the subject corporation's financial statements;              
          (3) the corporation's dividend-paying capacity, its history of              
          paying dividends, and the amount of its prior dividends; (4) the            
          nature of the corporation, its history, its position in the                 
          industry, and its economic outlook; (5) the corporation's                   
          management; (6) the degree of control transferred with the block            
          of stock to be valued; (7) any restriction on the transferability           
          of the corporation's stock; (8) the period of time for which an             
          investor must hold the subject stock to realize a sufficient                
          profit; (9) the corporation's redemption policy; and (10) the               
          cost of effectuating a public offering of the stock to be valued.           
          See Estate of Gilford v. Commissioner, supra at 60; Mandelbaum v.           
          Commissioner, supra; Rev. Rul. 77-287, supra.                               
               Additionally, a control premium may be appropriate when                
          valuing a large block of stock.  A control premium represents the           
          additional value associated with the shareholder's ability to               
          control the corporation through his dictation of its policies,              
          procedures, or operations.  See Estate of Chenoweth v.                      
          Commissioner, 88 T.C. 1577, 1581-1582 (1987); Estate of Trenchard           
          v. Commissioner, supra; Rev. Rul. 59-60, 1959-1 C.B. 237, 242.              
          This premium for control is distinct and separate from any                  

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