- 22 - enormously: On one end, market value of total capital exceeded net asset value plus debt by 75.4 percent; on the other, market value of total capital was less than net asset value plus debt by 42.2 percent. When market value of total capital exceeded net asset value plus debt, as it did for most of the REIT’s in his sample, Mr. Keath referred to this as a minority interest premium. His report suggests that for a majority of REIT’s, there is a substantial minority interest premium rather than a minority interest discount, and that the average REIT reflects a minority interest premium. The notion that there is a premium associated with a minority interest contradicts this Court’s precedents, the weight of expert commentary, and common sense. See, e.g., Estate of Newhouse v. Commissioner, 94 T.C. at 249. The fact that Mr. Keath’s data reflects this trend suggests that there is something wrong with his data, his analysis, or both. Conclusion: The Value of Decedent’s Shares in JFI As we have stated, we believe that Mr. Egan’s report is the most reliable and persuasive, and we accept his conclusions. Thus, we find that decedent’s 195 shares in JFI at the time of her death were worth $439 per share, or a total of $85,605. 12(...continued) a standard distribution for the REIT’s in his sample, but he offered no evidence of this fact.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011