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study is not entirely accurate. The Bajaj study states that the
14.09-percent discount, which Dr. Widmer focused on, is not
solely a reflection of marketability discount but is also
influenced by additional factors which have to be accounted for.
Bajaj et al., supra at 107. These factors depend on the fraction
of total shares offered in the placement, business risk,
financial distress of the firm, and total proceeds from the
placement. Id. at 107-109.
As we find the parties’ assumptions and analyses concerning
the marketability discount only minimally helpful, we use our own
analysis and judgment, relying on the parties’ experts’
assistance where appropriate. Helvering v. Natl. Grocery Co.,
304 U.S. at 295.
In McCord v. Commissioner, 120 T.C. at 394-395, we focused
on the Bajaj study and found that a 20-percent marketability
discount was appropriate for interests in a family limited
partnership classified as an investment company. Dr. Bajaj
divided the private placements into three groups according to the
level of discounts--the 29 lowest discounts, the middle 29
discounts, and the 30 highest discounts. Id. at 394. The low
discount group, with a discount of 2.21 percent, is dominated by
registered private placements which did not suffer from impaired
marketability. Id. The high discount group, with a discount of
43.33 percent, is dominated by unregistered private placements
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