Clarissa W. Lappo - Page 18

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               Dr. Shapiro concluded that these 15th-percentile REITs data            
          should be adjusted downward in petitioner’s favor to remove a               
          liquidity premium that is inherent in REITs; i.e., a premium that           
          arises because REIT interests, unlike the assets underlying them,           
          are publicly traded in reasonably liquid markets.  To gauge the             
          size of this inherent liquidity premium, Dr. Shapiro referred to            
          an academic study of private placement discounts for a period               
          ending just before the valuation dates for the subject                      
          partnership interests.  Bajaj et al., “Firm Value and                       
          Marketability Discounts”, 27 J. Corp. L. 89 (2001) (hereinafter             
          the Bajaj study).  On the basis of the Bajaj study, Dr. Shapiro             
          concluded that, for the relevant time period, liquid assets such            
          as REITs were trading at a premium of about 7.5 percent over                
          illiquid assets such as the partnership interests.  Subtracting             
          this 7.5-percent liquidity premium from the previously indicated            
          15th-percentile REITs data, he concluded that the real estate               
          component of the partnership interests should be valued to                  
          reflect minority interest discounts of 8.3 percent (-.8 minus               
          7.5) and 6 percent (1.48 minus 7.5), as of April 19, 1996, and              
          July 2, 1996, respectively.                                                 
               Dr. Shapiro then compared these results to his own study               
          which suggested that minority interests in holding companies                
          trade at a discount of 8.5 percent relative to controlling                  
          interests in holding companies.  Adjudging holding companies to             






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