- 25 - 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 thisPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011