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and respondent’s expert’s numerous recalculations were suspect,
not sufficiently explained, and not persuasive.
Also, we disagree with respondent’s expert that no discount
should be applied to the estate’s 20-percent interest to reflect
its minority status. In cases cited just in the parties’ briefs,
the following minority discounts are observed: 25 percent--N.
Trust Co. v. Commissioner, 87 T.C. 349, 389 (1986); 10 percent--
Estate of Heck v. Commissioner, T.C. Memo. 2002-34; 15 percent
and 20 percent--Gow v. Commissioner, T.C. Memo. 2000-93, affd. 19
Fed. Appx. 90 (4th Cir. 2001).
In cases cited in the parties’ briefs, the following lack of
marketability discounts are observed: 20 percent--N. Trust Co.
v. Commissioner, supra at 389; 30 percent--Estate of Desmond v.
Commissioner, T.C. Memo. 1999-76; 40 percent and 45 percent--
Barnes v. Commissioner, T.C. Memo. 1998-413; 30 percent--
Mandelbaum v. Commissioner, T.C. Memo. 1995-255, affd. without
published opinion 91 F.3d 124 (3d Cir. 1996); 30 percent--Estate
of Gallo v. Commissioner, T.C. Memo. 1985-363.
On the evidence before us in this case, we conclude that the
appropriate valuation of the estate’s 20-percent stock interest
in TPC, as of May 2, 1998, should be based on a capitalization of
TPC’s estimated sustainable net income for 1998-2002 calculated
as an average of TPC’s 1993-97 income with an additional $10
million per year in expenditures relating to projected Internet-
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