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of the corporation’s underlying net assets. See id. at
943. For that reason, the Commissioner argued that the
corporations should not be valued using earnings and
dividend-paying capacity. See id. In resolving that
dispute, we stated as follows:
[R]egardless of whether the corporation is seen
as primarily an operating company, as opposed to
an investment company, courts should not restrict
consideration to only one approach to valuation,
such as capitalization of earnings or net asset
values. * * * Certainly the degree to which the
corporation is actively engaged in producing
income rather than merely holding property for
investment should influence the weight to be
given to the values arrived at under the
different approaches but it should not dictate
the use of one approach to the exclusion of all
others. [Id. at 945; citations omitted.]
In this case we do not agree with respondent that the
net asset value approach is irrelevant on the ground that a
hypothetical buyer of the subject limited partnership
interest would have no control over when the underlying
property was sold or when the partnership was liquidated.
The net asset value should still be considered because the
value of the underlying real estate will retain most of its
inherent value even if the corporation is not efficient in
securing a stream of rental income. See id. at 944. Thus,
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