- 49 - This potential overlap and the apparent failure to separate the minority interest and marketability discounts cause us to question Mr. Heebink’s conclusion. On the other hand, Mr. Engstrom’s conclusion of a 25-percent marketability discount is reasonable under the circumstances of this case. Where appropriate, we consider a 15-percent minority interest discount and a 25-percent marketability discount in determining the fair market value of HII stock. Conclusion The record reflects a range of values per share for HII stock, which we summarize as follows: Redemption analysis - Mr. Heebink1 $104,000 Net asset value analysis - Mr. Engstrom1 119,000 Valuation analysis - Mr. Heebink1 128,000 Guideline companies analysis - Mr. Engstrom2 219,000 Prior redemption transaction - Mr. Engstrom3 329,500 Stockholders agreement - Mr. Engstrom3 380,000 1Minority interest and marketability discounts applied. 2Marketability discount applied only. 3No discounts applied. Because valuation necessarily results in an approximation, the valuation figure we determine need not be one as to which there is specific testimony as long as it is within the range of values that may properly be arrived at from consideration of all the evidence. See Estate of Magnin v. Commissioner, T.C. Memo. 2001- 31. After considering all the evidence, the values that petitioners’ and respondent’s experts derived in their various analyses, other factors, and appropriate minority interest andPage: 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