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Similarly, we reject Mr. Lax’s combined 60-percent minority
and marketability discount, because the studies that he relied on
dealt with transactions in limited partnership interests, not
general partnership interests.
We find respondent’s proposed 10-percent minority discounts
for interests transferred by Dave and Jean True to be
unsubstantiated and insufficient. Even though a general partner
in True Ranches may exert more control than a shareholder in a
public company or a limited partner in a publicly registered
partnership, he would not have unilateral control over business
decisions. Further, we reject respondent’s swing vote argument
regarding Dave True’s 38.47-percent interest owned at death, for
the reasons stated in our analysis of True Oil. See supra pp.
201-202.
Based on the record, we apply a 15-percent minority discount
to the controlling equity values computed by Mr. Kimball to
arrive at a marketable minority value for True Ranches of
$34,852,550 as of January 1, 1993, and $38,502,883 as of June 4,
and June 30, 1994.
2. Marketability Discounts
a. Kimball Reports
Mr. Kimball treated the subject interests in True Ranches as
not being readily marketable for the same reasons described in
the True Oil section of this opinion. See supra pp. 204-206.
Accordingly, Mr. Kimball applied 35-percent marketability
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