- 29 - asset-based value of the stock in question to some extent.12 Considering all the facts and circumstances, we think that a reduction in the amount of 5 percent of the built-in gains is appropriate. In light of the foregoing, we find that the net asset value of Dunn Equipment is equal to the asset value calculated under Mr. Frazier’s report ($7,519,439) plus the value of the townhouse ($35,000) and the amounts recorded as prepaid expenses ($52,643) and prepaid interest ($671,260), reduced by 5 percent of the amount of the built in gain of $7,109,000 ($355,450), resulting in a prediscount asset-based value for the entire company of $7,922,892. C. Combining the Values As previously discussed, we have decided that the fair market value of decedent’s stockholdings is best approximated by an allocation of 65 percent to the asset-based value of $7,922,892 and 35 percent to the earnings-based value of $1,321,740, resulting in an overall value of $5,612,489. Based upon these findings, the fair market value of decedent’s 62.96- 12 The effect of any inherent gain on the hypothetical buyer who wishes merely to continue operating the company has been taken into account in the earnings-based value discussed above, because the company sold equipment as part of its ongoing operations. Thus, we apply the reduction to the asset-based value only, rather than as part of an overall discount to the asset- and earnings-based values.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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