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In Estate of Jameson v. Commissioner, T.C. Memo. 1999-43, 77
T.C.M. (CCH) 1383, 1397, 1999 T.C.M. (RIA) par. 99,043, at 269-
99, we noted that the terms marketability and illiquidity are
closely related but are not interchangeable. Liquidity is a
measure of the time required to convert an asset into cash and
may be influenced by marketability. On the other hand,
marketability is not a temporal measure--it is a measure of the
probability of selling goods at specified terms, based on two
variables: Demand for the asset and existence of an established
market for buyers and sellers of that asset type. See id. Thus,
if the interest being valued had the power to liquidate the
corporation, then demand for the corporation’s assets (rather
than its stock) and existence of a market for such assets are
most relevant to our analysis of marketability. See id.
In the cases at hand, Dave True’s 68.47-percent interest
could control liquidation of Belle Fourche; therefore, we must
examine the marketability of Belle Fourche’s pipeline assets.
Petitioners did not address directly the demand for pipeline
assets in the region during the relevant period. However, based
on Mr. Gustavson’s conservative projections, a buyer could expect
the Belle Fourche pipeline to continue to generate cash-flow for
another 15 years. Moreover, the stiff competition in the region
suggests that larger pipeline owners might consider buying out
smaller pipeline operations rather than building new lines. This
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