- 42 - Willamette Management Associates (Willamette) and the testimony of Robert F. Reilly, the managing director of that firm.29 The Willamette report concludes that a 30-percent “illiquidity discount” would be appropriate. We found the testimony of Mr. Reilly and Mr. McGraw to be persuasive with respect to the propriety of an illiquidity discount and their reports in this matter to be well reasoned. The facts that PCAB was a small family company and the shares in the company could not be sold without the approval of Pepsi-Cola, Inc., favor the conclusion that some discount is appropriate.30 After carefully considering all the relevant evidence, including the expert reports and testimony, we consider an illiquidity discount of 25 percent to be appropriate. Control Premium As a general proposition, control is an element to be taken into account for purposes of determining the fair market value of corporate stock, over and above the value that is attributable to 29Mr. Reilly, among his other qualifications, has an M.B.A. degree in finance from Columbia University Graduate School of Business. He is an accredited senior appraiser as designated by the American Socy. of Appraisers, a Chartered Financial Analyst, a C.P.A., and he has coauthored a book entitled “Valuing a Business”. 30A lack of marketability discount was applied in a similar circumstance in Estate of Oman v. Commissioner, T.C. Memo. 1987- 71 (noting that it would be difficult to sell 75.6 percent of the stock in a family company to an outsider, particularly with decedent’s sons remaining active in the business, which justified the application of a marketability discount).Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
Last modified: May 25, 2011