9% of the Freeze Entity to determine the federal gift tax value of the Residual Units. (The special valuation rules of Section 2701 do not apply to the Managing Units because they represent a proportional interest in each economic interest in the Freeze Entity. Accordingly, 1% of the Freeze Entity's value will be

- Valuing the Managing Units Once the Freeze Entity's Adjusted Book Value is established, the first class of equity that typically gets valued are the Managing Units, since the Managing Unit's have the first claim on any distributions, including liquidating distributions, from the entity. The value of the Manag