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After analyzing the various market studies on illiquid
securities, Mr. Siwicki concluded that the lack of
marketability discount for the subject limited partnership
interest was most comparable to the portion of the SEC
study that reported a 30-percent discount for restricted
securities of nonreporting over-the-counter issuers.
However, Mr. Siwicki believed the subject limited
partnership interest warranted a greater discount due to
two differences. First, he found that there was no
prospect of a public market ever developing for this
interest. Second, he found that the restrictions on the
sale of this interest were perpetual, as opposed to the
restrictions in the studies which lasted for only 1 to 3
years. Thus, Mr. Siwicki concluded a 35-percent discount
represented the lack of marketability of the interest.
After applying this discount, Mr. Siwicki concluded that
the fair market value of the subject limited partnership
interest on the date of death was $971,838.
Mr. Siwicki's analysis is summarized as follows:
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