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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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