- 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.
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