từ cơ sở dữ liệu giá Pre-IPO Advisors. Trường hợp liên quan đến xác định giá trị của quà tặng cổ phiếu trên hai ngày khác nhau. Kể từ khi triển vọng cho thanh khoản từ xa, chuyên gia của người nộp thuế được lựa chọn chỉ có các giao dịch lớn nhất khối-kích thước liên quan đến cổ phiếu đang lưu hành từ cơ sở dữ liệu | 304 DISCOUNTS FOR LACK OF MARKETABILITY from the Valuation Advisors Pre-IPO database. The case involved the valuation of gifts of stock on two different dates. Since the prospects for liquidity were remote the taxpayer s expert selected only the largest-block-size transactions in relation to shares outstanding from the FMV Restricted Stock database. The relevance of block size to perceived holding period was explained in a previous section. Since the subject company was very large and studies show a lower discount for lack of marketability for larger companies than for smaller ones only transactions in stocks of companies with more than 100 million in sales were selected from the Valuation Advisors Pre-IPO Transaction database. Since the company paid no dividends and was not likely to for the foreseeable future only non-dividend-paying stocks were selected from both databases. The expert for the Service testified to 30 percent on both dates and the expert for the taxpayer testified to 45 percent on both dates. The court concluded that the appropriate discount was 40 percent on one date and 45 percent on the other date in addition to a 5 percent discount for nonvoting stock which the experts agreed to resulting in total discounts of 45 percent on one date and 50 percent on the other date. Excerpts from the court s opinion indicate the importance of strong empirical evidence and analysis Both experts relied on two sources of empirical data for aid in quantifying the discountfor lack of marketability 1 discounts on sales of restricted shares of publicly traded companies and 2 discounts on private transactions prior to initial public offerings IPOs . Based on these studies and an examination of the perceived risks facing a potential investor in SSE stock the estate s expert concluded that a 45 percent discount for lack of marketability was appropriate and the Service s expert concluded that a 30 percent discount was justified. The estate expert s reports contain a far
