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experts’ or parties’ assistance where appropriate. See Helvering
v. Natl. Grocery Co., 304 U.S. at 295; Silverman v. Commissioner,
538 F.2d at 933.
We find the factors considered in Mandelbaum v.
Commissioner, supra, to be a helpful guide to approaching the
question of the amount of marketability discount. We are unable
to give any weight to studies involving the companies Mr. Frazier
deemed comparable, because they were not sufficiently similar to
provide us with meaningful guidance regarding CCC. We do agree
with respondent that CCC’s financial performance justifies a
lower-than-average discount for lack of marketability. The
discount should be lower than average, even though CCC’s
dividends were lower than those of similar companies, because it
had a successful history of long-term appreciation. Because CCC
is a holding company with a diversified spectrum of marketable
blue chip securities, its performance is relatively reliable and
easily verified.
CCC’s financial outlook should also favor a lower-than-
average discount because there is no indication that CCC’s
portfolio or performance will change from its currently and
historically successful course. CCC’s management, as stipulated
by the parties, has performed well, a factor in favor of a lower-
than-average discount. The lack of control in the subject shares
should not cause the discount to vary significantly from the
average because a buyer of a 6.44-percent interest in CCC would
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