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in Belle Fourche. First, Black Hills Trucking was unprofitable,
unlike Belle Fourche. Second, Black Hills Trucking’s shareholder
distributions were negligible, while Belle Fourche’s were
significant. In fact, during the period analyzed, shareholders
lent or contributed substantial amounts to Black Hills Trucking.
Based on the foregoing, we conclude that a minority interest
in Black Hills Trucking was less marketable than a minority
interest in Belle Fourche. Therefore, we assign a 30-percent
marketability discount to Jean True’s 37.63-percent interest in
Black Hills Trucking transferred as of June 30, 1994.
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