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for each valuation, we are providing a single response that is applicable in both cases. We understand the IRS is seeking an explanation as to why Empire selected a lower, combined, lack of control and marketability discount of 15% rather than a higher one. Empire did consider, as a starting point i
Consultants, LLC ("Empire") provide a response to the IRS's request for an explanation of the lack of control and marketability discount applied in Empire's valuations of: (1) a 37.75% interest in Black Family Partners, LP ("BFP") as of October 25, 2013; and (2) a 34.53% interest in BFP as of December
ather than a higher one. Empire did consider, as a starting point in selecting an applicable discount, the information presented by the following: Mergerstat Review 2013, Mergerstat's Quarter Control Premium Study, Closed End Investments Companies, and the FMV Restricted Stock Study. The range from these studie
udy as guidance for selecting an applicable lack of control and marketability discount. While these items are referenced separately in our report, Empire determined that it was reasonable to select a combined lack of control and marketability discount that was below a combined level of the low end of
Consultants, LLC ("Empire") provide a response to the IRS's request for an explanation of the lack of control and marketability discount applied in Empire's valuations of: (1) a 37.75% interest in Black Family Partners, LP ("BFP") as of October 25, 2013; and (2) a 34.53% interest in BFP as of December
ormation regarding lack of control and marketability discounts presented in Empire's valuation reports. Empire considered information presented by Mergerstat Review 2013, Mergerstat's 3'd Quarter Control Premium Study, Closed End Investments Companies, and the FMV Restricted Stock Study as guidance for selecting
point of 24%. However, the appraisal, on page 70, concluded that the combined minority/marketability discount should be a total of 15%. Please have Empire provide a detailed explanation as to how a total 15% discount was arrived at as their appraisal leads to the conclusion that a much higher total di
ack of control discount regarding the transfer of the donors 34.53% Limited Partnership Interest in Black Family Partners, L.P. The appraisal cited Mergerstat Review 2013 and stated that the control premiums in Mergerstat corresponded to a discount for lack of control of 27%. The appraisal then cited Mergerstat'
Entities connected to both Empire and Mergerstat Review

Alan Dershowitz
PERSONAlan S. Halperin
PERSONLeon Black
PERSONWeiss
PERSONRifkind
PERSONWharton & Garrison LLP
ORGANIZATION
Rochester
LOCATIONMergerstat
PERSONWest Hartford
LOCATIONBlack Family Partners
ORGANIZATIONScott A. Nammacher
PERSONControl Premium Study
ORGANIZATION