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purposes and denying minority discount to voting stock because of
swing vote potential).
A comparison of the marketable minority values for True Oil
proposed by Mr. Kimball and by respondent follows:
Kimball reports’
Respondent’s net
Valuation guideline company
asset value method
date method
January 1, 1993 $37,253,000 $35,685,000
June 4, 1994 $34,623,000 N/A
June 30, 1994 $34,623,000 $30,780,000
We have acknowledged the merits of both parties’ valuation
methods and believe that some combination of the two methods
would most accurately measure True Oil’s marketable minority
value. However, Mr. Kimball’s values would require adjustments
for our stated concerns, which are likely to result in higher
values. As it is, we need not compute Mr. Kimball’s adjusted
guideline company values because respondent’s marketable minority
values (shown above) are less than Mr. Kimball’s as of January 1,
1993, and June 30, 1994. Thus, we accept respondent’s marketable
minority values as of January 1, 1993, and June 30, 1994, and
treat them as concessions.
Respondent did not determine True Oil’s marketable minority
value as of June 30, 1994, because he treated Dave True as owning
a controlling interest at death. However, we treat Dave True’s
38.47-percent interest in True Oil as a minority interest, and we
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