Robert T. and Mary F. Gow - Page 36




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          opinion as to the discount amounts, whereas respondent’s experts              
          did not.  We are not persuaded by respondent’s experts’ reasoning             
          in determining the quantum of the discounts.  The quantum of the              
          discount for lack of control ranged from a low of 5 percent at the            
          joint venture level to a high of 50 percent at the WVI level.                 
          Moreover, we are mindful that initially respondent’s experts                  
          believed a discount for lack of marketability was not appropriate             
          at the joint venture level, but eventually changed their minds and            
          applied a 10-percent discount.  In contrast, Mr. Gampel’s discount            
          rates were consistent and uniform, ranging from 15 percent for lack           
          of control at the joint venture level (20 percent for lack of                 
          control at the WVI level) to 30 percent for lack of marketability             
          at both levels.  Consequently, we adopt the quantum of the                    
          discounts for lack of control and lack of marketability at both               
          levels for both valuation dates as determined by Mr. Gampel.  Thus,           
          the valuation conclusions of Ms. Maiden and Ms. Kalmar should be              
          adjusted (reduced) to reflect Mr. Gampel’s discount amounts.  This            
          adjustment can be made by the parties in their Rule 155                       
          computation.                                                                  
               In reaching our conclusions, we have considered all arguments            
          raised by the parties in their posttrial briefs.  We reject, as               
          apparently did petitioners’ own expert, the argument (which                   
          petitioners’ counsel alleges was conceded by Ms. Kalmar during her            
          testimony) that the shares of WVI stock awarded to Dr. Gow have no            






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