- 10 - C. Minority Interest Discount In estimating the fair market value of a noncontrolling interest in a closely held business entity, it may be appropriate to decrease NAV to reflect lack of control inherent in the interest. See, e.g., Estate of Andrews v. Commissioner, 79 T.C. 938, 953 (1982). 1. Marketable Securities As previously indicated, with respect to the marketable securities component of the partnership interests, petitioner’s expert recommends a 7.5-percent minority interest discount, whereas respondent’s expert recommends an 8.5-percent minority interest discount. The parties agree that the difference is not significant. At trial, petitioner agreed to use respondent’s slightly higher net asset values for the marketable securities. Out of fairness to petitioner, we also use Dr. Shapiro’s slightly higher 8.5-percent minority interest discount rate. 2. Real Estate a. Selection of Guideline Companies Both experts agree that publicly traded real estate investment trusts (REITs) provide an appropriate starting point for determining the minority interest discount with regard to the partnership’s real estate holdings. They disagree, however, on which REITs should be used for comparison and on the analysis of the REITs data.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011