- 18 - 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 FLPPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: March 27, 2008