- 30 - After calculating the above $25,784,000 entity value for TPC, the estate’s experts calculated a prediscounted value for the estate’s 20-percent interest in TPC as follows: Value of TPC $25,784,000 Multiplied by Estate’s 20.57% Interest .2057 Prediscounted Value of Estate’s Interest$ 5,304,000 The estate’s experts then discounted the above $5,304,000 by applying a 40-percent minority interest discount and an additional 45-percent lack of marketability discount to arrive at a date-of-death value of $1,750,000 for the 487,440 shares of TPC common stock includable in decedent’s estate, as summarized below: Prediscounted Value of Estate’s 20.57% Interest$5,304,000 Less 40% Minority Interest Discount 2,122,000 Subtotal $3,182,000 Less 45% Lack of Marketability Discount 1,432,000 Value of Estate’s 20.57% TPC Stock Interest$1,750,000 The estate’s experts’ 40-percent minority interest discount was based primarily on their reading of general valuation texts.9 The estate’s experts’ 45-percent lack of marketability discount was based largely on the following factors: (1) The stated intent of TPC’s management that it had no interest in 9 Coolidge, “Survey Shows Trend Toward Larger Minority Discounts”, Estate Planning 282 (Sept. 1983); Coolidge, “Fixing Value of Minority Interest in a Business; Actual Sales Suggest Discount as High as 70%”, Estate Planning 141 (Spring 1975).Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
Last modified: May 25, 2011