In Re Marriage of Schorer v. Schorer
Accepting Bonfield’s valuation of canning business not clearly erroneous. Bonfield used a 20% premium because of husband’s controlling interest and a 20% discount for reduced marketability.
In Re Marriage of Popp v. Popp
Husband’s testimony alone insufficient to warrant discount factor for nonmarketability and minority position. Expert opinion needed.
In Re Marriage of Liddle v. Liddle
Discount for lack of control was proper.
Marriage of Arneson v. Arneson
25% discount for minority interest and lack of marketability affirmed.
Drumheller v. Drumheller
Appellate court affirmed trial court’s valuation which rejected proposed minority discount.
Owens v. Owens
No minority discount where husband owned 50 percent interest in a family-owned business and his brother owned the other 50 percent.
Kress v. United States
Discounts for lack of marketability found to be 27% and 25%. No premium or discount for S corporation.
Richarz v. Richarz
(1) A minority discount did not apply in valuing marital property consisting of husband’s interest in an LLC in which he was minority owner, where the LLC was a family LLC (2) A lack-of marketability discount did not apply either, since the primary value of the LLC was in real estate and it was unlikely a sale would ever occur.
Adams v. Adams
Discounts for lack of marketability and lack of control affirmed.
Clark v. Clark
Family court could determine that marketability discount was applicable to wife’s 25% interest in closely held family business. A lack of control discount was also reasonable.
Matter of Marriage of Brancomb
No minority or marketability discount where partnership agreement means that minority shares would never have to be sold on the open market.
Matter of Marriage of Barlow
Discount of 25% for 15% ownership of a family business affirmed. Higher discount rejected, as no minority sale was planned.
In Re Marriage of Williams
Trial court reversed for discounting corporation for lack of control where son and father each owned one-half.
Marriage of Danelson
Applying 40% discount to business in which each party had a 50% interest is reversed as husband had full control over corporate affairs.
Cox v. Cox
50 percent discount for lack of marketability affirmed.
Bernier v. Bernier
Trial court erred in using C-Corp tax rates for an S-Corporation. Also, the trial court erred in using “key man” and marketability discounts where the businesses (supermarkets) were not going to be sold.
In Re Marriage of Conner
Trial judge could not take judicial notice of discount of lack of marketability.
Miller v. Miller
Court affirmed for not applying marketability discount where company was highly marketable due to high return.
Brooks v. Brooks
Trial court erred by valuing interest in LLCs without examining lack of marketability and lack of control.
Siracusa v. Siracusa
No minority discount should be applied where the parties were sole shareholders and husband awarded 100% of the shares.
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