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to be $3,378,914. In order to arrive at the discount
attributable to the future tax, Mr. Wilde divided $3,378,914 (the
present value of the future tax) by $18,223,290 (the total value
of VIC's real estate and investments) to arrive at a 19-percent
(rounded from 18.5 percent) discount. Accordingly, Mr. Wilde's
discount is not calculated as a percentage of net asset value;
rather, it is calculated as a percentage of the value of VIC's
real estate and investment property. Mr. Wilde errs in
calculating the discount attributable to the tax on the built-in
gain this manner.
Mr. Wilde errs in that the present value of the future tax
should have been stated as a percentage of net asset value, not
as a percentage of only VIC's real estate and investments. The
estate correctly points out that the figure that Mr. Wilde
arrives at "is irrelevant for purposes of calculating the
percentage amount by which the taxes reduce the net asset value,
because it excludes some assets and all liabilities." As a
percentage of net asset value, the discount amount would not be
19 percent. The present value of the future tax, $3,378,914,
divided by Mr. Wilde's net asset value, $16,443,000 produces a
20.5-percent discount. Accordingly, after correcting that error,
the discount attributable to the tax on the built-in gains
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