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part and revd. and remanded in part on another ground 976 F.2d
1163 (8th Cir. 1992), we stated:
The values arrived at by * * * [the expert] were
the basis for the date of death values of the corporate
properties. * * * Because in appraising the
properties * * * [the expert] took into account the
market for such property, as well as general economic
conditions in Grand Forks, the fair market value of
Vaberg's corporate assets, and therefore the fair
market value of 100 percent of the Vaberg stock, has
already been adjusted for such conditions.
To the extent that the market for residential real
estate and general economic conditions would have a
negative impact on the fair market value of the 26.92
percent of Vaberg stock held by the decedent,
petitioner has already reduced the reported value of
the stock on account of such impact. For this Court to
adjust the discounts for minority interest and lack of
marketability for these factors would be to duplicate
the reduction in reported value due to such factors.
On the basis of our reasoning in Estate of Berg, supra, Mr.
Wilde's 5-percent increase in the net asset value discount
attributable to the general economic conditions of the Santa
Barbara area is inappropriate. Similarly, the 5-percent decrease
in the net asset value discount attributable to Mr. Wilde's
consideration of VIC's cash-flow and ability to pay dividends is
inappropriate pursuant to the reasoning of Rev. Rul. 59-60, 1959
C.B. 243, which is consistent with our conclusion in the instant
case. The estate additionally contends that Mr. Wilde's
adjustment for "Management Continuity" is already reflected in
the value of MVN and MVS. We do not agree.
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