- 10 - and Rocky Mount. Beck valued decedent’s housing partnership interests as follows: Total Value of Fred Jr.’s Entity the Partnership 50% Interest Monroe $469,307 $234,653 Clinton 158,391 79,196 Rocky Mount 187,287 93,643 Charlotte 198,005 99,003 Dvorak and Keith both qualify as experts on valuation of real estate, and Kaye and Beck qualify as experts on the valuation of businesses. On August 2, 1994, respondent mailed a notice of deficiency for Federal estate tax. The values of decedent’s 50-percent partnership interests determined by respondent in the notice were derived by averaging values of decedent’s interests as determined under a net asset approach and an income approach after applying a 10-percent discount for lack of marketability to each.3 The values were as follows: Partnership Income Value Asset Value Average Monroe $577,689 $337,125 $457,407 Clinton 186,039 72,933 129,484 Rocky Mount 439,960 320,782 380,371 Charlotte 390,087 309,692 349,890 GMA 431,356 230,020 330,688 In calculating income value, respondent applied a capitalization rate of 10 percent. 3 No lack of marketability discount was applied to the net asset value of GMA.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011