QOF Valuation Group · A subsidiary of AppraiseItNow

Fair market value of Qualified Opportunity Fund interests, for the December 31, 2026 inclusion

Deferred gain on every Opportunity Zone investment made through 2026 and still held at year end is included in income on December 31, 2026, and the amount included can turn on the fair market value of the investor's interest in the fund on that date. The draft 2026 Form 8997 adds a column for it. We value QOF interests for funds and their investors: the investor's own interest, through the fund's operating agreement, with discounts for lack of control (DLOC) and lack of marketability (DLOM) where the facts support them. Below are the rules that set the inclusion, a worked example, five recent discount engagements on closely held entities and fund interests, and the credentialed team behind our reports. Each engagement results in a full written report prepared in accordance with USPAP and Rev. Rul. 59-60, with a fixed fee quoted in an engagement letter before any work starts.

◆ In the case studies, client names, entity names, locations, and dollar values have been generalized to protect confidentiality. Discounts are shown as ranges.

◆ For illustrative purposes only. Every figure on this page, including discount ranges, is an approximation based on past engagements. None are the exact conclusions of any single report, and none are an indication or prediction of the outcome of any future valuation.

IRC §1400Z-2 · Form 8997

The December 31, 2026 inclusion, and where the value comes in

How the amount included is set, and what an appraisal of the interest does for it. Investors should confirm their own figures with their tax adviser.

Inclusion date

December 31, 2026

Deferred gain on Opportunity Zone investments made through December 31, 2026 and still held at year end is included in the taxable year that includes that date (IRC §1400Z-2(b)(1)). It cannot be deferred again, and the 10-year election survives (Notice 2026-40).

QOF corporations

Lesser of gain or value

The amount included is the lesser of the remaining deferred gain and the fair market value of the investment, less the investor's basis, which counts only the 5- and 7-year step-ups (IRC §1400Z-2(b)(2); Treas. Reg. §1.1400Z2(b)-1(e)(3)).

QOF partnerships and S corporations

A hypothetical sale

The amount included is the lesser of the remaining deferred gain less the step-ups, and the gain on a fully taxable sale of the interest at fair market value (Treas. Reg. §1.1400Z2(b)-1(e)(4)). Losses and distributions already passed through reduce what a lower value can save.

Basis step-ups

15% or 10%

Basis rises by 15% of the deferred gain for investments made by December 31, 2019, and by 10% for investments made by December 31, 2021. Later investments get no step-up (T.D. 9889, 85 FR 1892).

What is valued

The investor's interest

The asset is the investor's own interest in the fund, not a pro-rata share of its net asset value (Treas. Reg. §1.1400Z2(a)-1(b)(34)). A fund interest can carry discounts for lack of control and marketability; no IRS guidance addresses them on QOF interests either way, so they rest on the facts of each interest.

Reporting

Form 8997

The draft 2026 Form 8997 adds a fair market value column for recognizing the remaining deferred gain. No rule requires an appraisal, but the value the investor reports has to be supported.

Penalty defense

Independence

Reasonable cause and good faith turn in part on the appraiser's relationship to the taxpayer or to the activity (Treas. Reg. §1.6664-4(b)(1)). An independent appraisal is stronger support than a value the fund sets for itself.

Calendar

March 15, 2027

Values are as of December 31, 2026, and the valuation is finished after year end, once the fund closes its books. Calendar-year partnership K-1s are due March 15, 2027, and individual returns April 15, 2027.

Illustrative Example

$1,000,000 of gain deferred in 2019, three kinds of fund

With the 15% step-up, the most that can be included is $850,000. In each case the investor's interest is worth $600,000 on December 31, 2026. Tax at 23.8% (20% plus 3.8% net investment income tax), with no state tax.

	(a) QOF corporation	(b) QOF partnership, no debt	(c) QOF partnership, leveraged
Facts	Stock worth $600,000	Interest worth $600,000; no losses, income, or distributions	Equity worth $600,000; $400,000 of losses passed through and a $100,000 debt-financed distribution
Rule	Reg. §1.1400Z2(b)-1(e)(3)	Reg. §1.1400Z2(b)-1(e)(4)	Reg. §1.1400Z2(b)-1(e)(4)
Amount included	$450,000	$450,000	$850,000
Tax	$107,100	$107,100	$202,300
Tax saved by the appraisal	$95,200	$95,200	$0

In (c) the losses and the debt-financed distribution already lowered the investor's basis, so the hypothetical sale at $600,000 produces more gain than the cap and a lower value changes nothing; the appraisal would matter only below $500,000 of equity. Before ordering an appraisal of a partnership interest, compare the deferred gain with the losses and distributions on its K-1s. Illustrative only, not tax advice.

Discount Studies

Discount case studies at a glance

Five recent engagements valuing closely held entities and fund interests: the same analysis of control and marketability a QOF interest needs. Across them, total discounts ran from about 20% to 55%, set by the facts of each interest rather than the purpose of the report.

Engagement	Purpose	Approach	DLOC	DLOM	Total Effective Discount
Pre-development land holding	Estate & gift planning	Net asset value	25–40%	10–30%	45–55%
Ground-up multifamily development	Estate & gift planning	Income (DCF)	20–35%	10–30%	40–50%
Pre-IPO fund LP interest	Roth IRA conversion	Net asset value	25–40%	10–25%	40–50%
Diversified private fund LP interests	Gift tax reporting	Net asset value + income (DCF)	5–15%	10–35%	25–45%
Majority interest in a single-property LLC	Estate tax reporting	Net asset value	10–20%	10–20%	20–35%

Drivers

What moves the discount

Reports prepared for the same purpose can conclude very different discounts. These are the facts that matter most.

Factor	Larger discount	Smaller discount
Size and rights of the interest	Small minority with no vote	Majority interest, or a stake that can block major decisions
Distributions	None paid and none expected	Regular distributions
Underlying assets	One illiquid asset with little or no income	Cash, or a diversified portfolio
Market for the interest	No buyers and strict transfer limits	An active secondary market, as with many private equity fund interests
Expected holding period	Long and open-ended	Short or defined, such as a fund nearing the end of its term

Credentials

Our team

QOF Valuation Group is a subsidiary of AppraiseItNow, and its valuations are prepared by AppraiseItNow's credentialed business valuation team, led by our CEO. Click a profile to expand its full credentials overview.

Joe Kattan

Owner & CEO

Owner and CEO of AppraiseItNow. A former Bain & Company consultant, Joe acquired the firm in 2024 and has led its growth since, bringing Bain's standard of analytical rigor to how every valuation engagement is scoped, staffed, and reviewed.

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Joe is the owner and CEO of AppraiseItNow. Before acquiring the firm, he was a consultant at Bain & Company, where he advised executive teams on strategy, growth, and investment decisions. The work demanded rigor under deadline: framing the question that actually matters, building the analysis that answers it, and defending every number in the room. He holds AppraiseItNow's valuation work to that same standard, where a conclusion is only as strong as the evidence and reasoning behind it.

Joe acquired full ownership of AppraiseItNow in 2024 and has led its growth since, expanding the practice across business valuation, fine art, and complex machinery and equipment. He has also invested heavily in the firm's technology, so clients get faster answers and every report benefits from a consistent, well-supported process. He oversees engagement quality across the practice and matches each project to the right credentialed appraiser on the team.

Talon Stringham

CPA · ABV · CFE · ASA

Association of Certified Fraud Examiners

More than 24 years across business valuation, forensic and investigative accounting, and expert witness testimony. Talon has performed hundreds of gift and estate tax valuations without an IRS challenge on a valuation issue, with subjects ranging from early-stage ventures to an automotive group with over $1.1 billion in combined sales.

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Talon has spent more than 24 years in business valuation, forensic and investigative accounting, litigation support, and expert witness work. On the valuation side, he has performed appraisals supporting audited financial statements for both publicly traded and privately held companies, including purchase price allocations, 409A valuations, option, warrant, and convertible debt valuations, and goodwill impairment analyses. He has provided hundreds of valuations for gift and estate tax purposes while never being challenged by the IRS on a business valuation issue, and has valued closely held companies across a wide range of industries for financial statement preparation, ESOP, divorce, shareholder dispute, and other litigation purposes, including numerous family limited partnerships and holding companies.

His engagement history runs from early-stage bio and med-tech, software-as-a-service, and technology companies to large private groups. He served as lead valuation analyst on a high-profile Florida divorce valuation involving personal goodwill and a disputed value range exceeding $100 million, appraised every entity in a conglomerate of 19 automobile dealerships and 20 real property holding companies spanning 25 automotive and powersport brands with over $1.1 billion in combined sales, and led valuation work for a trucking company with sales in excess of $500 million in a shareholder buy-out.

On the forensic side, Talon has supervised and performed business interruption loss calculations, reconstruction of accounting records after theft, fire, and flood, and investigative accounting for criminal fraud trials, marital estates, and officer and director litigation. He has testified as an expert in personal injury, wrongful death, and wrongful termination matters, and helped defend a company against an alleged $1 billion patent and trade secret damages claim that ended in a judgment under $1 million. He also brings formal training in computer forensics and has recovered electronic evidence for divorce and employment law matters.

Talon earned a Bachelor of Arts in Accounting and a Master of Science in Accounting with a finance emphasis from Utah State University. He is a Certified Public Accountant licensed in Utah, an Accredited Senior Appraiser of the American Society of Appraisers, Accredited in Business Valuation by the AICPA, and a Certified Fraud Examiner. He has chaired the UACPA Business Valuation Committee, served as Treasurer of the Utah Chapter of Certified Fraud Examiners and of the Southern Utah Estate Planning Council, and wrote Understanding Business Valuation: An Owner's Guide to the Business Appraisal Process along with articles in The Utah Bar Journal and The Journal Entry, including Valuation Discounts for Holding Companies.

Justin Ramirez

ASA · ABV · CFA

Performs fair value and fair market value appraisals of companies and partnerships for tax and financial reporting, purchase price allocations, buy-sell agreements, and lending, with valuation roles at Gordon Brothers, Mercer Capital, and Weaver and Tidwell. Industry coverage runs from real estate holding companies to energy, industrial, and professional services.

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Justin performs fair value, fair market value, and net orderly liquidation value analyses of companies and partnerships for tax and financial reporting, purchase price allocations, mergers and acquisitions, buy-sell agreements, and lending purposes. His clients range from individuals and their counsel, including estate and probate attorneys, to family offices and the management teams of privately held and publicly traded companies.

He is a Manager of Global Valuations at Gordon Brothers and previously held valuation roles at Mercer Capital and at Weaver and Tidwell, formerly HSSK, where he also performed audit reviews of third-party valuations. His appraisal subjects span brand-oriented retail, capital-intensive industrial, energy and utility companies, real estate holding companies, and architectural and engineering firms, with pre-revenue work in biological and medical technologies and biopharmaceutical applications. He was a key contributor to a national energy valuation publication, has been cited in Oil and Gas Investor and the Midland Reporter-Telegram, and has testified as an expert in Texas district court matters.

Justin holds a Master of Science in Finance from the University of Houston and a Bachelor of Science in Economics from Texas A&M University. He is an Accredited Senior Appraiser of the American Society of Appraisers, Accredited in Business Valuation by the AICPA, and a CFA charterholder, and he has appeared as a guest speaker and panelist at the University of Houston and Texas A&M University.

Raymond Ghelardi

ASA

More than 35 years of valuation experience across tax and financial reporting, including leadership of national valuation practices at BDO's valuation arm and CBIZ Valuation Group, and review of valuations prepared by other experts.

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Raymond has over 35 years of experience valuing the securities and intangible assets of public and private corporations for financial reporting and tax purposes, including engagements under ASC 805, ASC 350, and 409A. He is the Managing Partner of Business Valuation Center's New York and Tampa offices and an executive of its parent holding company, and he has long been responsible for reviewing valuations prepared by other experts on behalf of accounting practice clients.

His career includes senior leadership across several national valuation practices: Director at GBQ Consulting, where he headed the New York office; Managing Director, Eastern Region Valuation Services at Ceteris; and Managing Director of Trenwith Valuation, the valuation arm of BDO, where he led teams on financial reporting and tax valuation projects and served as one of three members of the National Leadership Committee for BDO's valuation practice. Earlier, as Chairman of Valuation Counselors Group, he managed all aspects of the firm's business and rebuilt it into a national leader before directing its sale to CBIZ, a publicly traded company, in 1997. He also served as Senior Vice President at Management Planning, Inc. in Princeton, where he helped develop and implement the firm's corporate valuation practice.

Raymond holds an MBA from Emory University, a Master in City Planning from Harvard University, and a Bachelor of Science from Pennsylvania State University. He is an Accredited Senior Appraiser and Senior Member of the American Society of Appraisers and a past president of its Princeton chapter.

Andy Frew

ASA · ABV

More than 25 years of business valuation experience across hundreds of engagements, with a practice centered on closely held companies, holding companies, and noncontrolling ownership interests, and the discounts for lack of control and lack of marketability that come with them. Past president of the Houston chapter of the American Society of Appraisers.

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Andy has more than 25 years of business valuation experience and has participated in hundreds of valuation and related engagements across numerous industries. He values businesses and ownership interests for gift and estate tax, noncash charitable contributions, buy-sell agreements, mergers and acquisitions, business succession and exit planning, and litigation support.

Much of his work involves closely held companies, holding companies, and noncontrolling ownership interests. He regularly analyzes discounts for lack of control and lack of marketability, capital structures, shareholder and operating agreements, and the economic rights attached to privately held equity, and he also prepares and reviews valuations under buy-sell agreements. His industry experience includes oil and gas, particularly upstream exploration and production companies, as well as oilfield services, manufacturing, distribution, retail, automobile dealerships, and construction and building materials.

His career includes HFBE, where he began as an associate in 2000; Stout Risius Ross, where he was a Vice President; Ferguson Camp Poll, where he was a Director; and Forvis (formerly BKD), where he was a Senior Managing Consultant.

Andy holds a Bachelor of Business Administration in Finance from Texas A&M University. He is an Accredited Senior Appraiser in Business Valuation of the American Society of Appraisers and is Accredited in Business Valuation by the AICPA. A member of the American Society of Appraisers since 2007, he served as president of its Houston chapter from 2015 to 2016, and he belongs to the Houston Business and Estate Planning Council, the Houston Estate and Financial Forum, and the Financial Executives Networking Group.

Daniel Munoz

CVA

National Association of Certified Valuators and Analysts

Values closely held businesses, ownership interests, and financial instruments for gift and estate tax and noncash charitable contributions, in reports used with IRS Forms 709, 706, and 8283. His work extends to real estate holding companies, private equity interests, restricted and preferred shares, options, and warrants.

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Daniel has worked in business valuation since 2017, valuing closely held businesses, ownership interests, and financial instruments. His work covers financial statement analysis, valuation modeling, industry and market research, and the narrative reports and supporting schedules that document each conclusion. He has prepared valuations for federal gift and estate tax reporting and for noncash charitable contributions, used in connection with IRS Forms 709, 706, and 8283, as well as for management planning, ESOP reporting compliance, marital dissolution, and business purchases and sales.

His experience extends beyond operating companies to real estate holding companies, restricted and preferred shares, warrants, options, promissory notes, private equity interests, and undivided interests in real estate, where the analysis turns on the economic rights, restrictions, payment terms, and contingencies attached to the subject interest. He uses Black-Scholes option-pricing models and Monte Carlo simulation for instruments with option-like or contingent economic benefits, applies probability-weighted scenarios and sensitivity analysis to test how alternative outcomes, payment timing, and key assumptions affect the indicated value, and builds models for cash flow, market multiple, net asset, and option-pricing analyses with every material input and assumption documented.

His industry experience spans manufacturing, pharmaceuticals, assisted living, management consulting and staffing, banking and wealth management, real estate, plumbing and HVAC contracting, rail transportation, server hosting and internet businesses, communications, automobile dealerships, printing, mining and quarrying, restaurants and bars, and waste management. Before entering the valuation profession, he worked at CBRE as an accounting coordinator in account management, tax services, and general accounting.

Daniel holds a Bachelor of Science in Business with a concentration in Finance from DePaul University. He earned the Certified Valuation Analyst designation from the National Association of Certified Valuators and Analysts (NACVA) in 2018 and is a member of NACVA.

Talon, Justin, Raymond, Andy, and Daniel are a few of the appraisers on our valuation team. Our appraisers hold designations from the American Society of Appraisers (ASA), the AICPA (Accredited in Business Valuation, ABV), and the National Association of Certified Valuators and Analysts (Certified Valuation Analyst, CVA).

Client Reviews

What our clients say

Reviews from our clients and their advisors, posted on Google.

★★★★★

Reached out to Joe and Team in a difficult spot. A client gifted 5 Private Market LPs to a trust and needed a valuation and had a 5 week window to get it done. We had a call with Joe and he outlined what information was needed and provided an estimated cost. We received a detailed engagement letter with final cost. Joe was confident his team could get the job done on time. We received the draft valuation in approximately 4 weeks which needed to be reviewed by tax and legal counsel. When it was all said and done the final report was delivered a couple days earlier than originally promised which was a huge weight lifted off the client and his advisors. Communication is key and AppraiseItNow did a great job from start to finish and delivered exactly what they promised. Great experience!

Ryan T.Business valuation for gift tax · Annapolis, MD

★★★★★

Responsive, professional, first class deliverables -- especially considering that that the appraised assets are extremely complex financial assets with little by way of comps. The deliverable satisfied my accountants and advisers as being more than adequate to support the valuation needed to complete a conversion to a Roth IRA

David T.Business valuation for a Roth IRA conversion · Ocala, FL

★★★★★

We had an excellent experience working with Appraise It Now for our company. From start to finish their team was professional, responsive, and incredibly thorough. They took the time to understand our specific needs and delivered a detailed, accurate appraisal that was well organized and easy to understand.
Communication was clear and timely throughout the entire process and they were always available to answer questions and explain anything we needed further clarity on. Their attention to detail and knowledge of the market gave us complete confidence in the final report.
It is clear they take pride in their work and genuinely care about providing high quality service. We would absolutely recommend Appraise It Now to any business or property owner looking for a reliable and professional appraisal company. Five stars all the way.

Heather D.Las Vegas, NV

★★★★★

I used AppraiseItNow to examine a contribution to a foundation. Their work was quick and thorough, and easy to interface with as they have developed a system for simple uploading of documents. I plan to use them again,

Jeff H.Business valuation for a charitable contribution · New York, NY

★★★★★

I was in need of highly specialized appraisal services and appraiseitnow was able to accurately complete the appraisal and meet all the required standards. The market based valuation seemed very fair, and their process and documentation factually supported this. Their customer service is outstanding, they were professional throughout the process and the turnaround time was very prompt. I would not hesitate to use them again.

Scott H.Rangeley, ME

★★★★★

We used the Appraiser services and were very satisfied with the results. Fast and efficient communication, understanding our company's needs, on-time delivery of the report, as well as reasonable price point. Highly recommend.

Ekaterina M.San Francisco, CA

★★★★★

This team is so easy to work with. They are very professional and pleasant, and respond quickly to any questions. They are knowledgeable and complete their appraisal quickly. I feel their fee is reasonable for the work they do. They are properly licensed so I feel they can be trusted, especially after speaking with them. It is clear they know what they are talking about. Their process is easy to follow and complete. I highly recommend the AppraiseItNow team and look forward to working with them again.

Janet K.Vero Beach, FL

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In Depth

Detailed case studies

The full mechanics behind each engagement summarized above: the subject interest, the valuation approach, and the drivers behind each discount. Case Studies 01 to 03 sit at the high end of the range: minority interests with no vote or no distributions, each holding a single asset. Case Studies 04 and 05 show how diversification, distributions, and control rights bring the discount down.

Case Study 01

Minority interest in a pre-development land holding entity

Pre-Development Stage

Subject Interest

Minority membership units in a single-asset LLC

Underlying Asset

100+ acre undeveloped land tract (Southeast US) with nominal lease income and no structures

Valuation Approach

Net asset value: third-party real estate appraisal less outstanding debt, then discounted at the interest level

Report Use

Fair market value support for estate and gift planning

Discount for Lack of Control

25–40%

No distributions, with none anticipated; net asset yield under 1%
Benchmarked against published non-distributing partnership data and closed-end fund discounts
Portfolio concentration in one non-income-producing asset
Restrictions on disposition; shallow management depth
Offset: small member group simplifies coordination

■ Amber items reduced the discount

Discount for Lack of Marketability

10–30%

Pre-revenue asset with no performance history
No market for units; severe transfer restrictions
Very long expected holding period with no distribution offset
Material debt against a non-income-producing asset

Total effective discount45–55%

Case Study 02

Non-voting minority interest in a completed ground-up multifamily development

Ground-Up Real Estate

Subject Interest

Minority, non-voting membership units in a single-asset LLC

Underlying Asset

Newly delivered multifamily property (Southeast US), developed ground-up over multiple years, in initial lease-up at the valuation date

Valuation Approach

Income approach: discounted cash flow on debt-free net cash flow with a market-derived WACC and terminal growth rate

Report Use

Fair market value support for estate and gift planning

Discount for Lack of Control

20–35%

All decisions reserved to a majority of the voting class; subject units carry no vote
Benchmarked against published partnership and closed-end fund discount data for leveraged, distributing entities
Single-asset concentration and thin management depth
Offset: small member group simplifies coordination

■ Amber items reduced the discount

Discount for Lack of Marketability

10–30%

No established operating history; property still in lease-up
Significant leverage on a single asset
Severe transfer restrictions in the operating agreement; no market for units
Long expected holding period
Offset: prospective rental income supports future distributions

■ Amber items reduced the discount

Total effective discount40–50%

Case Study 03

Minority LP interest in a single-asset pre-IPO feeder fund

IRA Conversion

Subject Interest

<2% limited partner interest

Underlying Asset

Single-purpose fund holding preferred shares of one late-stage private company

Valuation Approach

Net asset value from the fund's capital account statement, then discounted at the interest level

Report Use

Fair market value support for a traditional-to-Roth IRA conversion

Why this one concluded high: the fund held a single non-yielding position and paid nothing until an exit. Diversified, distributing funds conclude lower (see Case Study 04).

Discount for Lack of Control

25–40%

LPs hold zero management or voting rights; all authority rests with the GP
Transfers require GP consent in its sole discretion
No withdrawal or redemption rights
Single-asset portfolio concentration
Small, key-person-dependent management team
No yield; benchmarked against closed-end funds with comparable concentration

Discount for Lack of Marketability

10–25%

No public market for LP interests; severe contractual transfer restrictions
No distributions until a liquidity event at the underlying company
Supported by restricted stock and pre-IPO studies plus a full Mandelbaum factor analysis
Offset: strong secondary demand for the underlying company and a credible near-term IPO path compressed the holding period

■ Amber items reduced the discount

Total effective discount40–50%

Case Study 04

Minority LP interests in several diversified private funds

Diversified Funds

Subject Interest

Small limited partner interests in several private funds, transferred together

Underlying Asset

Diversified portfolios across buyouts, growth equity, and distressed and opportunistic credit, several of them in their harvest or liquidation periods

Valuation Approach

Net asset value from audited financial statements and capital account statements, discounted at the interest level, weighted equally with a discounted cash flow of expected distributions under two realization scenarios per fund

Report Use

Fair market value support for federal gift tax reporting

Discount for Lack of Control

5–15%

LPs hold no management or voting rights; the GP controls investments, exits, and the timing of distributions
Benchmarked against closed-end funds grouped by asset class and investment strategy
Provision-by-provision review of each fund's partnership agreement
Offset: diversified portfolios rather than a single holding
Offset: ongoing distributions and defined fund terms

■ Amber items reduced the discount

Discount for Lack of Marketability

10–35%

No public market for LP interests; transfers require GP consent
Remaining realization periods of roughly two to ten years, depending on the fund
Unfunded commitments and recallable distributions can require further capital from the holder
Supported by restricted stock studies, a private-company DLOM database, and fund-specific holding-period analysis
Offset: an active secondary market for private fund interests
Offset: funds closest to the end of their term carried the smallest discounts

■ Amber items reduced the discount

Total effective discount25–45%

Case Study 05

Majority interest in a single-property real estate LLC

Majority Interest

Subject Interest

Majority membership interest (over 90%) in a two-member LLC

Underlying Asset

One resort condominium (Western US) held for rental, with moderate mortgage debt

Valuation Approach

Net asset value: third-party real estate appraisal less outstanding debt, then discounted at the interest level

Report Use

Fair market value support for federal estate tax reporting

Discount for Lack of Control

10–20%

The minority member's consent is required for distributions, a sale of the property, and dissolution
Benchmarked against publicly traded real estate closed-end funds, which traded near net asset value
Offset: the interest holds the large majority of voting rights and controls day-to-day management and the choice of manager
Offset: one identifiable, appraised asset with moderate leverage

■ Amber items reduced the discount

Discount for Lack of Marketability

10–20%

No market for the interest; transfers require the other member's consent
No redemption or withdrawal rights; uncertain multi-year holding period
Supported by restricted stock studies and a full Mandelbaum factor analysis
Offset: the remaining member or a strategic buyer is a natural purchaser
Offset: transparent, appraised underlying asset

■ Amber items reduced the discount

Total effective discount20–35%

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