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35-percent minority interest discount should apply to
petitioner’s April 19, 1996, gifts, and a 30-percent minority
interest discount to her July 2, 1996, gift. In addition, Mr.
Oliver concluded that there should be a 35-percent marketability
discount for each gift.
2. Respondent’s Expert
Respondent’s expert, Dr. Alan C. Shapiro (Dr. Shapiro), is
the Ivadelle and Theodore Johnson Professor of Banking and
Finance and past chairman of the Department of Finance and
Business Economics, Marshall School of Business, University of
Southern California (USC). He is also an outside director of
LECG, LLC, an economic and financial consulting company. Prior
to joining USC in 1978, he taught at the Wharton School of
Business at the University of Pennsylvania and has been a
visiting professor at Yale, the University of California at Los
Angeles, the University of British Columbia, and the Stockholm
School of Economics. He is the author of numerous academic
articles and books on corporate finance.
In his direct testimony, Dr. Shapiro concluded that the
partnership interests should be valued to reflect an 8.5-percent
minority interest discount and an 8.3-percent marketability
discount.
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Last modified: May 25, 2011