- 14 - disclosed by management.” Comparing these NAVs to quoted share prices, Mr. Oliver concluded that the median price-to-NAV discount for the guideline companies was 29.3 percent on April 19, 1996, and 20.3 percent on July 2, 1996. Mr. Oliver then considered a number of factors that he said differentiated the partnership from his seven guideline companies. On the one hand, he concluded, the partnership had a “much stronger” financial position than the guideline companies, which would indicate a relatively smaller price-to-NAV discount for the partnership interests. On the other hand, he concluded, certain factors augured for a deeper price-to-NAV discount: The partnership had “very small” real estate holdings compared to the guideline companies; it was dependent on just one primary tenant; and as a newly formed entity, it lacked a track record of operations. The net effect of such factors, Mr. Oliver concluded, was that a minority interest investor would value the partnership’s real estate component at a deeper discount than the guideline median price-to-NAV discount. In the final analysis, he concluded that the appropriate minority interest discount was 35 percent for petitioner’s April 19, 1996, gifts of partnership interests and 30 percent for petitioner’s July 2, 1996, gift. Mr. Oliver has inadequately explained how he derived the NAVs that are critical to his computation of the price-to-NAVPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011