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limited partnership interests reported in the studies. However,
he found that True Ranches interests were less liquid than the
reported partnerships because True Ranches had not made recent
distributions as of the valuation date and the interests were not
publicly traded. Thus, Mr. Lax chose a 60-percent combined
discount to reflect the increasing trend of average discounts
reported in the studies.
d. Respondent’s Position
Respondent offered no expert testimony or other evidence
regarding True Ranches’ total equity value as of the relevant
dates. Instead, respondent has adopted Mr. Kimball’s adjusted
net asset values of $41,003,000 as of January 1, 1993, and
$45,297,509 as of June 4 and June 30, 1994.
Respondent argues that interests in True Ranches transferred
individually by Dave and Jean True to their sons as of January 1,
1993, and June 30, 1994, respectively, were entitled to minority
discounts of no more than 10 percent. Additionally, respondent
argues that the 38.47-percent interest owned by Dave True at
death is not entitled to a minority discount, because it
represented a significant ownership block that had swing vote
potential.
Based on the foregoing, respondent proposes marketable
minority values for the True Ranches interests transferred as of
January 1, 1993, and June 30, 1994, of $36,902,700 and
$40,767,758, respectively. Respondent argues that the marketable
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