- 34 -
circumstances. Therefore, a further discount for built-in
capital gains is not appropriate in this case.
D. Conclusion
The schedules below summarize our conclusions as to fair
market value for the transferred JBLP and AVLP limited
partnership interests:
83.08-Percent Interest in JBLP
NAV of limited partnership $ 7,704,714
83.08%
Pro rata NAV 6,401,076
Lack of marketability (8%) (512,086)
Fair market value $ 5,888,990
16.915-Percent Interest in AVLP
NAV of limited partnership $11,629,728
16.915%
Pro rata NAV 1,967,168
Secondary market (40%) (786,867)
1,180,301
Lack of marketability (8%) (94,424)
Fair market value $ 1,085,877
We have considered all remaining arguments made by both
parties for a result contrary to those expressed herein, and, to
the extent not discussed above, they are irrelevant or without
merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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