- 176 - Notice, AA Hypothetical Value, WMA Hypothetical Value, and Current IRS Value. A footnote to the “Current IRS Value” column in each schedule stated: “These values reflect respondent’s agreement to allow combined minority interest and marketability discounts of up to 40 percent.” For the most part, petitioners prepared Exhibit 262-P and then furnished it to respondent for his review and approval. However, respondent provided petitioners with the “Current IRS Value” information and text for the related footnote. On February 16, 1999, the first day of trial, the parties filed a stipulation of facts and a supplemental stipulation of facts. The stipulations did not refer to “Current IRS Value[s]” or the combined minority and marketability discounts mentioned in Exhibit 262-P. However, the stipulations stated that respondent was no longer asserting adjustments in the value of transferred interests in certain companies, each of which had a “Current IRS Value” that approximated its “Return Value/Book Value”. Respondent’s trial memorandum, dated January 28, 1999, stated: In [his] notice of deficiency respondent allowed no discounts to the underlying values of the transferred interests. Respondent has indicated to petitioners that minority and marketability discounts of up to 40% should be applied in determining the fair market values of the transferred interests. In addition, “Current IRS Value[s]” differed from values reported in the statutory notices because the “Current IRS Value[s]”Page: Previous 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 Next
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