Estate of H.A. True, Jr. - Page 162




                                       - 238 -                                        
          might explain why Belle Fourche purchased the Thunderbird                   
          pipeline in 1992.  For these reasons, we find that Belle                    
          Fourche’s pipeline assets were marketable.                                  
              Based on the record, we apply a 20-percent marketability                
          discount in valuing Dave True’s 68.47-percent interest in Belle             
          Fourche as of June 4, 1994.  This level of marketability discount           
          on a controlling interest is within the range previously allowed            
          by this Court.  See, e.g., Estate of Jones v. Commissioner, 116             
          T.C. 11 (2001) (allowing an 8-percent marketability discount on a           
          83.08-percent controlling interest); Estate of Maggos v.                    
          Commissioner, T.C. Memo. 2000-129 (allowing a 25-percent                    
          illiquidity discount on a 56.7-percent interest conveying                   
          effective operational control);  Estate of Hendrickson v.                   
          Commissioner, T.C. Memo. 1999-278 (allowing a 30-percent                    
          marketability discount on a 49.97-percent effectively controlling           
          interest); Estate of Jameson v. Commissioner, supra (allowing a             
          3-percent marketability discount on a 98-percent controlling                
          interest).                                                                  
              To determine the appropriate marketability discount for Jean            
          True’s 17.23-percent interest in Belle Fourche transferred as of            
          June 30, 1994, we draw from our earlier discussion of                       
          marketability discounts applicable to minority interests in True            
          Oil.  In our True Oil analysis, see supra pp. 213-214, we began             
          with Mr. Kimball’s 40-percent discount, presumably derived from             







Page:  Previous  228  229  230  231  232  233  234  235  236  237  238  239  240  241  242  243  244  245  246  247  Next

Last modified: May 25, 2011