One issue at hand between the parties is the lack of marketability discount rate used to value the revocable trust’s 50.5% interest in CI LLC. Petitioners contend that a 31.7% rate is appropriate while the respondent finds a 7.5% discount is sufficient, resulting in an approximately $40 million difference in value of the interest in question. At the time of death, Koons’ 50.5% interest included a 49.94% voting interest and 51.59% nonvoting interest. Upon his death, the children’s total interest in CI LLC would increase to 70.93% with 70.42% voting interest and 71.07% nonvoting interest. Because a voting interest that results from Koons’ death would enable the trust to sell most of its interest in the entity and receive approximately $140 million, this was the minimum distribution from the interest and as such, the respondent’s finding that the interest would only be worth $110 million after discounts is improper.