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In a report prepared for this Court in valuing decedent’s
interests, Beck concluded that a lack of marketability discount
of 25 percent and a lack of control discount of 15 percent should
apply to the values derived in his valuation of Fred Jr.’s
interests in the housing partnerships, which would result4 in
values as follows:
Partnership Value
Monroe $149,591
Clinton 50,487
Rocky Mount 59,697
Charlotte 63,114
In addition to the partnerships in issue, at the time of his
death, decedent and Fred Jr. each owned 50 percent of the stock
of Godley Realty, Inc. (Godley Realty), and decedent owned a 25-
percent interest and Fred Jr. owned a 75-percent interest in
Concrete Panel Systems, Inc., of North Carolina (CPSI). In the
notice of deficiency, respondent determined that the value of
decedent’s interest in Godley Realty was $225,048 as of the
valuation date and the value of decedent’s interest in CPSI was
$34,271 as of the valuation date.5 Respondent’s valuations of
Godley Realty and CPSI were based, in part, upon the November 11,
1990, balance sheets, which reflect accounts payable to the five
4 In his trial testimony, Beck clarified that the
compounding of these two discounts would produce a total discount
of 36.25 percent.
5 The parties have stipulated that these values are
correct.
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