- 17 - provides a marketable, minority ownership indication of value. Id. at 304. Under this method, a discount from the listed value is typically warranted in order to reflect the lack of marketability of the unlisted stock. Mandelbaum v. Commissioner, T.C. Memo. 1995-255, affd. without published opinion 91 F.3d 124 (3d Cir. 1996). If the stock to be valued by the market approach represents a minority interest, no discount for the lack of control is applied because the method reflects a minority interest. If, on the other hand, the stock represents a control interest, a control premium is warranted in order to reflect the increased value over the minority value determined under the market valuation method. Estate of Desmond v. Commissioner, T.C. Memo. 1999-76. A discounted economic income approach can produce either a control value or a minority value, depending on the assumptions used in determining the economic income projections and the discount rate. Where the method used values the stock as if it were a controlling interest, no control premium is necessary because the control aspect has already been accounted for within the unadjusted value. Pratt, supra at 303-306. “The most common example of economic income projections that would lead to a minority or control value is whether or not owners’ compensation is adjusted to reflect value of services rendered.” Id. at 304.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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