- 29 - 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:Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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