- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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