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percent minority interest discount and a 40-percent marketability
discount, the fair market value of the gifted interest on the
valuation date was $522,609. Mr. Stryker did not separately
calculate the fair market value of the sold interest.
C. Respondent’s Expert
Respondent offered Francis X. Burns as an expert witness to
testify concerning the value of the transferred interests. Mr.
Burns is managing director of InteCap, Inc., a financial
consulting firm that specializes in valuation services. He has
been performing valuation services for approximately 15 years and
has testified as an expert in several valuation cases. The Court
accepted Mr. Burns as an expert in valuation and received into
evidence as his expert testimony his written analysis regarding
the value of the transferred interests.
In his written report, Mr. Burns concludes that, based on a
4.4-percent minority interest discount and a 15-percent
marketability discount, the fair market values of the gifted
interest and the sold interest on the valuation date were
$742,071 and $872,794, respectively.
IV. Discussion
A. Net Asset Value of the Partnership
Mr. Dankoff’s firm valued the assets petitioner contributed
to the partnership (the contributed assets) at $2,013,765. In
his written report, Mr. Dankoff acknowledges that such figure
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