Rhett Rance Smith and Alice Avila Smith, et al. - Page 18




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          After his 1995 valuation, sometime around 1999-2000, Mr. Kramer             
          advised petitioners to hire a certified appraiser.                          
               On April 5, 2000, Rance, as president of Beneco, retained              
          Management Planning, Inc. (MPI), to prepare economic and                    
          financial analyses and evaluations of Beneco, and three limited             
          partnerships (Jireh, Mustard Seed, and Zerubbabel) for a fee of             
          $12,500.  Mr. Koehl of MPI transmitted by a letter dated November           
          19, 2001, an evaluation of the “common stock of Beneco, Inc.,” as           
          of March 31, 2000, concluding that the aggregate freely traded              
          equity capital of Beneco had a value of $9,195,000.                         
               Mr. Koehl opined that the average lack of marketability                
          discount for private placements of nonpublicly traded stocks was            
          27.5 percent, and he decided to use a lack of marketability                 
          discount of 7.5 percent because he was valuing a controlling                
          interest.  Mr. Koehl concluded that the outstanding common stock            
          of Beneco had a fair market value of $8.5 million (or $8,500 per            
          share, based on 1,000 shares issued and outstanding) as of March            
          31, 2000, on a going-concern controlling-interest basis.  Mr.               
          Koehl and MPI did not prepare a separate valuation of                       
          petitioners’ limited partnerships, Jireh, Mustard Seed, or                  
          Zerubbabel.  Mr. Koehl’s valuation of Beneco contained the                  
          statement that it was prepared for management information, income           
          tax reporting, and other corporate purposes.  Mr. Koehl’s                   
          valuation did not contain a date for any contributions of an FLP            







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