-6- 15-percent minority interest discount and a 30-percent lack of marketability discount to the values derived under those methods. The book value method reflected Glenwood Bank’s reported equity as of June 30, 1996, the most current data available as of decedent’s date of death. The discounted cashflow method applied a 14.5-percent discount rate to Glenwood Bank’s projected annual income for each of the years during a 10-year period ending in December 2005 and an 11.5-percent rate to the bank’s residual value. The public guideline market method reflected prices paid for companies which were engaged in a business similar to Glenwood Bank’s and whose stock was actively traded in a public market. The private guideline market method reflected transactions involving acquisitions of privately held banks comparable to Glenwood Bank. The resulting values derived under these four methods were as follows: Discounted Public Private Book Cash Guideline Guideline Value Flow Market Market Value before discounts $14,135,000 $11,100,000 $14,000,000 $18,200,000 15-percent minority interest discount 2,120,250 n/a n/a 2,730,000 Marketable minority interest value 12,014,750 11,100,000 14,000,000 15,470,000 30-percent lack of marketability discount 3,604,425 3,330,000 4,200,000 4,641,000 Nonmarketable minority interest value 8,410,325 7,770,000 9,800,000 10,829,000 Subject percentage interest 11.6 11.6 11.6 11.6 Resulting value of subject interest 975,598 901,320 1,136,800 1,256,164 The average of the resulting values is $1,067,470.50 ((975,598 + 901,320 + 1,136,800 + 1,256,164)/4). At trial, petitioners called three experts to testify in support of petitioners’ challenge to respondent’s determination of the fair market value of decedent’s shares. Each of thesePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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