Estate of William G. Adams, Jr. Deceased, George W. Saenger, Executor - Page 15




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          converted the capitalization rate from after corporate tax to               
          before corporate tax because the tax character of both his                  
          estimated net cashflows for WSA and unconverted capitalization              
          rates is after corporate tax.                                               
               We conclude that Shriner improperly increased the                      
          capitalization rate from 20.53 percent to 31.88 percent.7                   
               4.   Conclusion                                                        
               The following shows the value of decedent’s interest in WSA            
          on September 28, 1995, before applying a discount for lack of               
          marketability:                                                              
          Normalized net cashflows                        $595,746                    
          Capitalization rate                              � 20.53%                   
          Capitalized net cashflows – total entity      1$2,901,831                   
          Equity interest of 61.59 percent                 x .6159                    
          Value of decedent’s interest                  2$1,787,238                   
               1  $595,746/.2053 = $2,901,831.                                        
               2  Before discount for lack of marketability.                          
          E.   Discount for Lack of Marketability                                     
               Both experts applied a discount for lack of marketability              
          because there was no ready market for WSA stock on September 28,            
          1995.  We agree that a discount for lack of marketability is                
          appropriate.                                                                



               7  The result here of a zero corporate tax on estimated                
          prospective cashflows and no conversion of the capitalization               
          rate from after corporate tax to before corporate tax is                    
          identical to the result in Gross v. Commissioner, T.C. Memo.                
          1999-254, affd. 272 F.3d 333 (6th Cir. 2001), of zero corporate             
          tax rate on estimated cashflows and a discount rate with no                 
          conversion from after corporate tax to before corporate tax.                





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