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trier of fact, we have broad discretion in assigning the weight to
accord to the various factors and in selecting the method of
valuation. Estate of O'Connell v. Commissioner, 640 F.2d 249, 251-
252 (9th Cir. 1981), affg. on this issue and revg. in part T.C.
Memo. 1978-191. In reaching our ultimate valuation conclusions, we
have considered and given the weight we deem appropriate to these
factors.
In valuing stock in closely held corporations, discounts are
usually warranted. A discount for lack of marketability may apply
to minority interests in closely held corporations because a ready
market for shares in the corporations does not exist. See, e.g.,
Estate of Jung v. Commissioner, supra; Estate of Jameson v.
Commissioner, T.C. Memo. 1999-43; Estate of Furman v. Commissioner,
T.C. Memo. 1998-157; Mandelbaum v. Commissioner, T.C. Memo. 1995-
255, affd. without published opinion 91 F.3d 124 (3d Cir. 1996);
Estate of Lauder v. Commissioner, T.C. Memo. 1992-736; Estate of
Andrews v. Commissioner, supra at 953.
In several instances, courts have held that hypothetical
buyers will pay a premium for shares with voting privileges or
conversely apply a discount for nonvoting stock. See Barnes v.
Commissioner, T.C. Memo. 1998-413 (a 3.66-percent discount was
applied for nonvoting stock); Kosman v. Commissioner, T.C. Memo.
1996-112 (a 4-percent discount was applied for nonvoting stock);
Estate of Winkler v. Commissioner, T.C. Memo. 1989-231 (voting
shares accorded a 10-percent premium); Wallace v. United States,
566 F. Supp. 904, 917 (D. Mass. 1981) (voting shares accorded a 5-
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