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transferred interests. Because petitioner has failed to carry
his burden of persuading us that a figure in excess of 25 percent
would be appropriate, we utilize a 25-percent marketability
discount for purposes of determining the fair market value of the
transferred interests.
D. Valuation Conclusion
We conclude that the fair market values of the gifted
interest and the sold interest on the valuation date were
$644,446 and $757,972, respectively, determined as follows:25
Total NAV $2,010,370
1 percent of NAV 20,104
Less: 6-percent minority
interest discount (1,206)
Marketable value 18,898
Less: 25-percent
marketability discount (4,725)
FMV of 1-percent interest 14,173
FMV of 45.47-percent interest 644,446
FMV of 53.48-percent interest 757,972
To reflect the foregoing,
Decision will be entered
under Rule 155.
25 For ease of computation, we determine the fair market
value of a 1-percent interest.
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