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competent to testify as to the value of his property, e.g., Juden
v. Commissioner, T.C. Memo. 1987-302, affd. 865 F.2d 960 (8th
Cir. 1989); Root v. Commissioner, T.C. Memo. 1981-330; O’Rourke
v. Commissioner, T.C. Memo. 1981-279, Simone did not convince us
that the prices set in the 1987 redemption agreement reflected
adequate and full consideration. The weight to be given to the
testimony of an owner of property as to the value of the property
depends upon the owner’s knowledge, experience, method of
valuation, and other relevant considerations. E.g., Root v.
Commissioner, supra; O’Rourke v. Commissioner, supra. In 1987,
Simone had less than a 1-percent ownership interest in the
company, and that interest he obtained by gift. His testimony as
to value was based, in part, on the 1987 appraisal, which is not
in evidence as an expert witness report. Simone also stood to
profit by a low estate tax valuation of the decedent’s shares.
We accord no weight to Simone’s testimony as to what was adequate
and full consideration in 1987.
On January 4, 1988, the company redeemed all of Poesch’s
common stock for $290 a share. That transaction occurred not
long after decedent entered into the 1987 redemption agreement,
and, for that reason, might be considered some evidence of
whether the price to be paid for the decedent’s stock under the
1987 redemption agreement reflected adequate and full
consideration in money or money’s worth as of the date of that
agreement. See, e.g., Estate of Andrews v. Commissioner, 79 T.C.
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