- 33 -                                         
          Accordingly, the discount percentages represented by that type of           
          transaction are inapposite.                                                 
               Next, Hulberg addressed what he called the “Fractional                 
          Discounting Method”.  That method was set out in an April 1992              
          journal article, Davidson, “Fractional Interests in Real Estate             
          Limited Partnerships, The Appraisal Journal, Apr. 1992, at 184-             
          194, in which 10 factors were used to analyze the amount of a               
          fractional interest discount.  The factors employed, include:               
          “Relative risk of the assets held, Historical consistency of                
          distributions, Condition of the assets, Market’s growth                     
          potential, Portfolio diversification, Strength of management.”              
          Those factors, to which Hulberg assigned values to arrive at an             
          estimated 41-percent discount, appear to be the type of factors             
          that are used in analyzing a going partnership business and not             
          the simple coownership of raw land.  The remaining four factors             
          address the control aspects, or lack thereof, of a fractional or            
          partial interest.  Of the cumulative 41-percent discount reached            
          by Hulberg, only 12 percent of it was attributable to the lack of           
          marketability/control factors.  The remaining factors depended              
          heavily on the fact that the entity was a going partnership                 
          (income sources, etc.) and would, therefore, not be applicable to           
          measure the partial interest discount in this case.                         
               Next, Hulberg used a “REIT Survey Method” that “involves an            
          analysis of discounts found in real estate investment trust                 
          (REIT’s).”  Hulberg indicated that the average discount was 39              
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