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to participate in the management or conduct of partnership
business, to require access to information about partnership
transactions, or to inspect or copy the partnership books and
records. See Wyo. Stat. Ann. sec. 17-21-503(a) (Michie 1999). A
transferee of a partner’s transferable interest is entitled to
receive current or liquidating distributions to which the
transferor would otherwise be entitled. The transferor retains
the rights and duties of a partner other than an interest in the
distributions transferred. See Wyo. Stat. Ann. sec. 17-21-503(b)
and (c) (Michie 1999).
The denial of management rights to a transferee interest
would make it less marketable than a partnership interest. See
Adams v. United States, 218 F.3d 383 (5th Cir. 2000). A
hypothetical purchaser could not count on being admitted into
partnership with the close-knit True family and would factor any
uncertainty regarding his ownership rights and privileges into
his offering price. See Estate of Newhouse v. Commissioner,
supra at 230-233. Thus, we agree with the conclusion of the
Kimball reports that this is a value-depressing factor.
On the other hand, we are troubled by the lack of any clear
connection between the Kimball reports’ general discussion of
restricted stock and pre-IPO studies and the marketability
discounts applied to the True Oil subject interests. For
instance, there was no showing that the industries represented in
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