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He reduced the aggregate value of the real properties of Marrero
Land on the valuation date by the amount of that capital gains
tax in order to arrive at the net proceeds from real properties
"in liquidation". Mr. Moore added the value of the other assets
owned by the Company on the valuation date to those net proceeds
to arrive at what he characterized as total assets of the Com-
pany. He reduced those total assets by the aggregate liabilities
that the Company had as of the valuation date to arrive at what
he termed the liquidation value of the Company, viz.,
$36,799,147. Mr. Moore applied a minority discount of 23 percent
to that liquidation value, which resulted in what he character-
ized as an implied market capitalization of $28,335,343. He
determined what he described as the implied public market value
of decedent's interest in Marrero Land on the valuation date by
multiplying the implied market capitalization by the percentage
interest in Marrero Land that decedent owned on that date. Mr.
Moore then applied a 35-percent lack-of-marketability discount to
the implied public market value of decedent's interest in Marrero
Land on the valuation date to arrive at a value of that interest
under the liquidation value approach of $6,146,153. Mr. Moore
considered the liquidation value approach to be "significant".
Mr. Moore indicated in his expert report that he was in-
structed by respondent to ignore the effect of amended article VI
and the voting trust in determining the fair market value of
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