- 237 - 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. ThisPage: Previous 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 242 243 244 245 246 Next
Last modified: May 25, 2011