Charles T. McCord, Jr. and Mary S. McCord, Donors - Page 65

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          to the net asset value of MIL’s assets to determine the fair                
          market value of the gifted interest.  Such a discount is commonly           
          referred to as a “marketability discount”.  The marketability               
          discount analyses of Mr. Frazier and Dr. Bajaj differ from their            
          minority interest discount analyses in that they seek to identify           
          a single, “entity-wide” discount rather than a weighted average             
          of discount factors specific to each category of assets held by             
          MIL.  The parties disagree as to the amount of that discount.               
                    2.  Traditional Approaches to Measuring the Discount              
                    a.  In General                                                    
               Mr. Frazier and Dr. Bajaj agree that empirical studies of              
          the marketability discount fall into two major categories.  The             
          first major category, the IPO approach, consists of studies that            
          compare the private-market price of shares sold before a company            
          goes public with the public-market price obtained in the initial            
          public offering (IPO) of the shares or shortly thereafter.  The             
          second major category, the restricted stock approach, consists of           
          studies that compare the private-market price of restricted                 
          shares of public companies (i.e., shares that, because they have            
          not been registered with the Securities and Exchange Commission,            
          generally cannot be sold in the public market for a 2-year                  
          period)32 with their coeval public-market price.  Mr. Frazier               


               32  See 17 C.F.R. sec. 230.144(d)(1) (1996).  The required             
          holding period was shortened to 1 year in 1997.  See 62 Fed. Reg.           
          9242 (Feb. 28, 1997).                                                       




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