- 48 - Discounts The parties and their experts agree that a 15-percent minority interest discount should be applied where appropriate to reflect the lack of control inherent in a minority interest in HII stock. They also agree that a marketability discount is appropriate to reflect the lack of a ready market for the HII stock on the gift date. However, they disagree as to the appropriate marketability discount to be applied: Mr. Heebink applied a 30-percent discount, and Mr. Engstrom applied a 25- percent discount. Our review of Mr. Heebink’s report shows a potential overlap and an apparent failure to make a proper separation between the lack of control and the lack of marketability apparent in a minority interest in HII. See Estate of Andrews v. Commissioner, 79 T.C. at 953 (explaining the difference between minority interest discount and marketability discount). Mr. Heebink states that “Minority interest shares are significantly less marketable and liquid than controlling interest shares because few investors are interested in minority interest investments in closely held companies”, and he concludes: Considering that this valuation relates to a minority interest in a company with extensive owner involvement, significant technical expertise, high earnings and profitability variation, and above average automobile industry concentration, a 30% marketability and liquidity discount was selected for Hess Industries.Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
Last modified: May 25, 2011