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Generally, if the inputs in the valuation model reflect
changes that only a control owner would (or could) make
(e.g., changed capital structure, reduced owner’s
compensation, and so on), then the model would be
expected to produce a control value. * * *
If the economic income projections merely reflect
the continuation of present policies, then the model
would be expected to produce a minority value. * * *
Id. at 194-195.
Under a discounted cashflow analysis, a discount rate based on
a traditional capital asset pricing model relates to marketable,
minority ownership in the investment to be valued. Issues of
control and lack of marketability are usually treated separately
rather than incorporating them in the discount rate. Id. at 162-
163.
If an indication of value is developed on the basis of
acquisition data, applying a minority interest discount is usually
appropriate when valuing a minority ownership interest. Id. at
305. However, “if the benchmark for the estimated sale price is
valuation multiples observed in acquisitions of public companies,
data indicate that valuation multiples for acquisitions of private
companies tend to be less.” Id. at 354.
In this case, the parties relied on expert testimony to
establish the fair market value of the trust’s 1,226 shares of JPMS
as of the moment of decedent’s death. The estate offered the
expert reports and testimony of George B. Weiksner and Kenneth W.
McGraw, and respondent offered the report and testimony of Martin
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