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rate that we determined using Mr. Oliver’s methodology and data,
modified as discussed above.
2. Further Adjustments
a. Petitioner’s Expert
Mr. Oliver ultimately concluded that the marketability
discount applicable to the partnership interests should be 35
percent, or 5.7-percent higher than the 29.3-percent median
discount that he determined by reference to his private placement
sample. He made this upward adjustment to his recommended
marketability discount on the basis of the following
considerations: The partnership is closely held with no real
prospect of becoming publicly held; the partnership is relatively
small and little known; there is no present market for the
partnership interests; the partnership agreement requires the
partnership to be offered the right of first refusal to purchase,
at a 15-percent discount, limited partnership interests; and the
partnership agreement permits a transferee of a limited
partnership interest to become a substituted limited partner only
with the general partners’ consent.
b. Respondent’s Expert
Dr. Shapiro ultimately concluded that the marketability
discount applicable to the partnership interests should be 8.3
percent, or 1.1-percent higher than the 7.2-percent discount that
he said was indicated by the Bajaj study. In arriving at this
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