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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.
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