- 12 - and therefore assigned a zero percent. As for the holding period, Mr. Wahlgren opined that neither the Company nor the Bank would be sold within 10 years because Mr. Janda wanted to continue to operate the Bank for as long as possible and, in any event, Robert Janda wanted to manage the bank thereafter. With regard to the holding period return of 21.47 percent, Mr. Wahlgren considered the risk-free yield on U.S. Treasury bonds, the difference between long-term yields on common stock over intermediate U.S. Government bonds, and a small stock premium. Respondent challenges Mr. Wahlgren’s use of the QMDM model on the basis that there is no evidence that appraisal professionals generally view the QMDM model as an acceptable method for computing marketability discounts. Respondent also asserts that the data used by Mr. Wahlgren in the QMDM model is inaccurate. We recognized in Estate of Weinberg v. Commissioner, T.C. Memo. 2000-51, that “slight variations in the assumptions used in the [QMDM] model produce dramatic difference in results.” The effectiveness of this model therefore depends on the reliability of the data input into the model. We have serious reservations with regard to the assumptions made by Mr. Wahlgren. For example, we are concerned whether in determining the growth rate of the Company, it was proper for Mr. Wahlgren to simply average the Bank’s historical returns on equity for the 5 years prior to December 31, 1992, and thenPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011