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the income stream a 3-year average of the cash
distributions made during the years 1990 through 1992,
$683,333 (i.e., total distributions during 3-year period,
$2,050,000, divided by 3). In calculating the average
distributions, Mr. Siwicki did not adjust the average to
take into account the final mortgage payment due on
April 1, 1993.
A 25.235-percent share of the 3-year average of cash
distributions (i.e., the share attributable to the subject
limited partnership interest) is $172,439 (i.e., $683,333
x 25.235 percent). Mr. Siwicki capitalized that amount,
$172,439, by 11 percent, the approximate yield of an
interest in IDS Balcor, to arrive at $1,567,627 as the
value of the subject limited partnership interest.
As mentioned above, the parties agree, for purposes
of this case, that the fair market value of the Hill House
apartment complex on the date of death was $10,050,000.
On the basis of the financial statements of Hill House
for 1992 and the fair market value of the property as
stipulated by the parties, Mr. Siwicki determined that the
net asset value of Hill House on the date of the decedent’s
death was $10,332,769. Thus, the subject 25.235-percent
interest in the net asset value of Hill House was
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