Estate of Frazier Jelke III, Deceased, Wachovia Bank, N.A., f.k.a. First Union National Bank, Personal Representative - Page 21

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          that would have been incurred each year over this 16-year period-           
          -$3,226,680.25 ($51,626,884 divided by 16).  Next, he selected a            
          13.2-percent discount rate based on the average annual rate of              
          return for large-cap stocks in the period from 1926 to 1998, as             
          described in Ibbotson Associates Stocks, Bonds, Bills &                     
          Inflation, 1999 Yearbook (Ibbotson 1999).  He then computed the             
          present value of the $3,226,680.25 annual tax liability                     
          discounted over 16 years using a 13.2-percent interest rate to              
          arrive at a present value for the total capital gain tax                    
          liability of $21,082,226.  By reducing the $188,635,833 net asset           
          value by the $21,082,226 future tax liability, Mr. Shaked arrived           
          at a $167,553,607 value for CCC.  Finally, Mr. Shaked concluded             
          that the undiscounted value for decedent’s 6.44-percent interest            
          in CCC was $10,789,164 in contrast to Mr. Frazier’s undiscounted            
          value of $8,823,062.  This difference reflects numerically the              
          parties’ differing approaches to the amount of capital gain tax             
          that should be used to reduce the net asset value of CCC.                   
               A hypothetical buyer of CCC is investing in a composite                
          portfolio to profit from income derived from dividends and/or               
          appreciation in value.  A hypothetical buyer of CCC is, in most             
          respects, analogous to an investor/buyer of a mutual fund.  The             
          buyer is investing in a securities mix and/or performance of the            
          fund and would be unable to liquidate the underlying securities.            
          That is especially true here where we consider a 6.44-percent               








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