- 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
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