- 50 - figures of Peoples, Mr. Fuller determined the following total equity values: Ratio Total Value Price-to-earnings $24,751,000 Price-to-book equity 19,344,000 Price-to-assets 21,021,000 Mr. Fuller then used the mean of the values determined using the price-to-book equity and price-to-assets ratios to determine a total equity value of $20,200,000. He did not include the value determined using the price-to-earnings ratio, as he thought the “unusually high earnings reported for the period may result in the value of Peoples being overstated.” Finally, Mr. Fuller applied a 10-percent marketability discount. Mr. Fuller supported his finding of a 10-percent marketability discount in his discussion of both marketability and control premium factors. He concluded that little or no marketability discount was appropriate, because the estate shares carried significant elements of control and might command a control premium. Mr. Fuller failed to focus on the fact that two conceptually distinct adjustments were involved, one a discount for lack of marketability and the other a premium for the benefits of control. See Estate of Andrews v. Commissioner, 79 T.C. 938, 952-953 (1982). Although there may be some overlap, because control, or lack of it, is a factor that may affect marketability, even controlling shares in a nonpublic corporationPage: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 Next
Last modified: May 25, 2011