- 45 - dividends, respectively, by multiplying the respective implied market capitalizations of Marrero Land using those factors by the percentage interest of decedent in the Company as of that date. Finally, Mr. Moore applied a 35-percent lack-of-marketability discount to each of those implied public market values to arrive at the following values of decedent's interest in Marrero Land on the valuation date using earnings, book value, and dividends, respectively: $7,255,468, $6,812,280, and $7,266,956. According to Mr. Moore, the public market multiples "approach is essen- tially a different way of valuing the improved real estate. To our view, it is a less exact approach than the discounted net asset value approach which utilizes the appraised value of the improved real estate investments." Under the liquidation value approach, Mr. Moore applied a 10-percent bulk sales discount to the aggregate value of the real properties owned by Marrero Land on the valuation date, which he determined by relying on, inter alia, Mr. Guice's value of the remaining unimproved real properties. The resulting product was what Mr. Moore characterized as the liquidation value of Marrero Land's real properties as of the valuation date. He reduced that liquidation value by the book value of those real properties to determine what he described as "Capital gain in liquidation". Mr. Moore applied a 34-percent capital gains tax rate to that capital gain, resulting in a capital gains tax of $12,293,109.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
Last modified: May 25, 2011