In Re Marriage of Davies
No discount for minority control where husband had minority interest, but had the ability to control operations. Also, no discount because value was determined by value of underlying assets.
In Re Marriage of Gay
Trial court properly distributed minority shares in business to each party where court found that valuation was too speculative.
In Re Cottrell
Valuation of dental practice based on capitalization of earnings is affirmed.
In Re Marriage of Lewis v. Lewis
(1) Valuation of professional partnership: focus is on monetary consequence if a partner withdraws; (2) Cross-purchase agreements can be considered in determining a partnerships worth and (3) A pet boarding business is a commercial business, not a professional partnership.
Marriage of Arneson v. Arneson
(1) 25% discount for minority interest and lack of marketability affirmed and (2) Presumption that buy-sell controls does not apply where it does not fix a specified price, but only an ongoing process for determining price.
In Re Marriage of Weiss v. Weiss
Accounts receivable and secured accounts receivable were improperly excluded from marital estate.
In Re Marriage of Ondrasek v. Ondrasek
Generally, value of interest in professional partnership is consequences of withdrawing, such as a buy out agreement. Here, where there was no agreement, court must consider the accounts receivable.
In Re Marriage of Liddle v. Liddle
Discount for lack of control was proper.
In Re Marriage of Popp v. Popp
Husband’s testimony alone insufficient to warrant discount factor for non-marketability and minority position. Expert opinion needed.
In Re Marriage of Schorer v. Schorer
Accepting Bonfield’s valuation of canning business not clearly erroneous. Bonfield used weighted average earnings record and used net book value to calculate the asset value.