- 23 - Another factor which makes Mr. Heebink’s analysis less persuasive is his application of a minority interest discount to the total business enterprise value he determined in his analysis. A significant component of this total business enterprise value is attributable to his market comparable analysis. Applying a minority interest discount to the market comparable analysis, which already reflects transactions involving minority interests, is inappropriate. See Estate of Mitchell v. Commissioner, T.C. Memo. 2002-98 (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). We do not agree with respondent that Mr. Heebink’s discounted cashflow analysis is entitled to no consideration. We will consider Mr. Heebink’s valuation analysis, bearing in mind the circumstances identified above, especially the fact that his analysis significantly understated the value of HII stock in making the erroneous adjustment for the alleged understatement of reserves.23 22(...continued) in valuing HII stock. However, we agree that it detracts from the persuasiveness of Mr. Heebink’s conclusions. 23Mr. Heebink does not present an alternative valuation which does not contain this adjustment; however, it is clear that this adjustment, if corrected, would bring Mr. Heebink’s conclusions considerably closer to those of Mr. Engstrom’s. (continued...)Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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