- 30 - percent interest in Dunn Equipment, before application of appropriate discounts, is $3,533,623. III. Discounts The parties agree that a 15-percent lack of marketability discount is appropriate.13 Further, respondent concedes that a 7.5-percent discount for lack of super-majority control, i.e., for the fact that the stock in issue is less than 66-2/3 percent, is also appropriate. Petitioner argues on brief for a 10-percent discount for lack of super-majority control. Neither Mr. Frazier nor Mr. Pratt provided support for a discount for lack of super- majority control, and petitioner offers no evidence supporting a discount greater than 7.5 percent. We apply a discount of 7.5 percent for lack of super-majority control. Therefore the discounts, in total, equal 22.5 percent. IV. Conclusion We have calculated an undiscounted value of petitioner’s 62.96-percent interest in Dunn Equipment on the date of decedent’s death of $3,533,623. Applying a 22.5-percent discount to this figure, we find that the fair market value of the stock in issue for purposes of the Federal estate tax is $2,738,558. 13 On brief, respondent agreed that the lack of marketability discount could properly be applied to the earnings- based value. Further, respondent agreed that the lack of marketability discount could properly be applied to an asset- based value generally but argued that it should not be applied to liquidation value. As we have not used liquidation value, we need not address respondent’s argument.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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