- 29 - not contemporaneous to the 1997 valuation year because they were gathered in the mid to late 1960s and early 1970s. Mr. Dorman also provided a brief discussion on minority discounts which concluded with the statement that an analysis of “Tax Court cases between 1950 and 1982 * * * disclosed a median 25-percent minority discount.” Following this general discussion of marketability and minority discounts, Mr. Dorman, in an attempt to summarize his commentary, referenced a study by Professor Steven E. Bolten which concluded that on the basis of other studies in existence as of 1984, average discounts for marketability and minority were 39.86 percent and 29.37 percent, respectively. Neither party’s expert attempted to persuade us to rely or not to rely on the various studies he referenced. Mr. Dorman’s discount approach focuses more specifically on Godfrey’s unique attributes and therefore provides a more direct approach to evaluate the interest in Godfrey. Additionally, we do not accept respondent’s expert’s position that no minority discount should apply where value is estimated by means of an income approach. Although Mr. Dorman’s approach is more subject specific, no foundation or background is provided to support the indexing in each category in the matrix. In that regard, the matrix was created by Mr. Dorman’s company and is obviously subjective. Finally, as explained below, we do not agree with parts of Mr.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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