- 13 - (upon which petitioner’s other expert, Mr. Stryker, relied as well)7 is based on values reported in brokerage account statements as of November 30, 1997 (5 days after the valuation date). Respondent’s expert, Mr. Burns, concludes in his written report that the value of the contributed assets on the valuation date was $2,008,370.8 We accept Mr. Burns’s conclusion in that regard.9 Taking into account the $2,000 in cash contributed by the other partners of the partnership, we conclude that the partnership’s NAV on the valuation date was $2,010,370. B. Minority Interest (Lack of Control) Discount 1. Introduction Pursuant to the partnership agreement, a hypothetical buyer of all or any portion of the transferred interests would have limited control of his investment. For instance, such holder (1) would have no say in the partnership’s investment strategy, and (2) could not unilaterally recoup his investment by forcing the partnership either to redeem his interest or to undergo a complete liquidation. The parties agree that the hypothetical 7 Mr. Stryker also inappropriately added approximately $640 of interest earned by the partnership in December 1997. 8 Mr. Burns actually identifies that figure as the partnership’s NAV. In doing so, he overlooks the $2,000 contributed by the other partners, which the parties have stipulated. 9 Although the parties stipulated that, for purposes of the notice of deficiency, respondent relied on the valuation of the contributed assets by Mr. Dankoff’s firm, the parties did not stipulate the accuracy of that figure.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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