- 37 - resulted in Dr. Bajaj’s determination of an overall 35-percent discount, which he treats, in total, as a marketability discount. Dr. Spiro determined a basic 15-percent liquidity discount,12 increased by an additional 10 percent for risks associated with Korbel’s status as an S corporation. Thus, Dr. Spiro’s total liquidity discount is 25 percent, which he applies to the values that he determined under his market and income approaches (i.e., values exclusive of the value of nonoperating assets). Dr. Spiro applied specific, separate discounts to nonoperating assets: A 25-percent minority discount followed by his overall 25-percent liquidity discount applicable to “excess land”13 and a 25-percent minority discount applicable to “excess cash”. b. Marketability Versus Minority Discounts We have recognized that there is a distinction between a discount for lack of marketability and a discount for the minority position of the interest to be valued. As we stated in Estate of Andrews v. Commissioner, 79 T.C. 938, 953 (1982): The minority shareholder discount is designed to reflect the decreased value of shares that do not convey control of a closely held corporation. The lack of marketability discount, on the other hand, is 12 We interpret Dr. Bajaj’s references to a “marketability” discount and Dr. Spiro’s references to a “liquidity” discount as references to the same type of discount. 13 Because Dr. Spiro applies the two discounts consecutively, the total discount is 43.75 percent: 0.25 + (0.25 x 0.75) = 0.4375.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
Last modified: May 25, 2011