- 43 - Using the 14.3-percent discount rate he calculated under CAPM, Mr. Fuller calculated discounted present values of $3,480,000 and $4,660,000 for Peoples' FCF for the valuation horizon, and its terminal value, respectively, for a value from operations of $8,140,000. He then added back the book value of the nonoperating assets, net of a 10-percent minority discount, to arrive at a total equity value of $19,770,000 ($6,590 per share). There are significant shortcomings in Mr. Fuller’s application of CAPM in this case that highlight our doubts over the appropriateness of its application to the valuation of small, closely held companies. As we said recently, "CAPM is a financial model intended to explain the behavior of publicly traded securities", and we "do not believe that CAPM and WACC are the proper analytical tools to value a small, closely held corporation with little possibility of going public." Furman v. Commissioner, T.C. Memo. 1998-157, 75 T.C.M. (CCH) 2206, 2214, 1998 T.C.M. (RIA) par. 98,157, at 868-98. Unlike the market contemplated by CAPM, the market for Peoples stock, to the extent one even exists, is not efficient, liquid, or free of significant transaction costs. Moreover, in relation to other closely held corporations, the liquidity of a financial institution is even further reduced by the fact that acquisitions and dispositions ofPage: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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