- 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.
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