- 28 - Because rent increases under the lease historically have lagged behind increases in the PPI, and in light of the uncertainty about the magnitude and direction of changes in PPI annual averages over a period as long as the 32 years remaining on the lease term at the time of petitioner’s gifts, we conclude that it is appropriate to take into account historical patterns of actual rents under the lease. On the basis of our review of all the expert reports and testimony, we conclude that Lipscomb’s projection of a 5.2-percent rent increase every 3 years for the duration of the lease is fair and reasonable. b. Present Value of Projected Rental Payments In determining the 1991 present value of the projected rental payments, a critical factor is the discount rate applied to the projected lease income stream. Lipscomb selected a discount rate of 8 percent, as representing “what a typical investor would have expected for investments of this type of land.” His report indicates that although the investment was “low-risk”, a higher discount rate was warranted owing to the limited marketability of the investment. Lipscomb applied the 8-percent discount rate to the after-tax lease income stream (assuming a 35-percent tax rate). Dilmore selected a discount rate of 13.5 percent, consisting of a 12.5-percent “basic discount rate” and an additional 1 percent to reflect the lack of a reforestation clause in the lease. Dilmore’s report states that he selected the 12.5-percentPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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