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discount by 5 percent to reflect the perpetual restrictions
on this interest and the slim prospect of the interest ever
being publicly traded. We believe that Mr. Siwicki failed
adequately to take into account certain characteristics of
the subject limited partnership interest that suggest a
decrease in the marketability discount. These factors
include consistent dividends, the nature of the underlying
assets, and a low degree of financial leverage.
Based on all the evidence of record, we find that a
marketability discount of 20 percent should be applied to
the subject limited partnership interest.
Valuation
Based upon the entire record of this case, we find the
date-of-death fair market value of the subject limited
partnership interest is $1,309,650.64. Our analysis is
summarized in the following schedule:
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