Johann T. and Johanna Hess - Page 49

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          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 and              





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