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