- 46 - 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 ofPage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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