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companies. Mr. Herber has not persuaded us that these factors
support a lower minority interest discount.
c. Our Analysis
We are unsatisfied that either expert has adequately
supported his recommended minority interest discount. The
estate does not argue for a minority interest discount greater
than 17 percent. Mr. Herber, who started with a minority
interest discount range of 18.4 to 19.6 percent before making
various adjustments that we do not find well supported, has not
persuaded us that the minority interest discount should be less
than 17 percent. Accordingly, we hold that a 17-percent minority
interest discount is appropriate in valuing decedent’s shares of
RBI stock.
2. Lack of Marketability Discount
Mr. Schroeder determined a lack of marketability discount of
40 percent, and Mr. Herber determined a lack of marketability
discount of 25 percent. Both experts used information from
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