- 21 -
that decedent's stock was worth $1,043,7339 on that date.
Respondent subtracted $1,043,733 from the $5 million in insurance
proceeds CSB paid to decedent’s estate to calculate how much of
the insurance payment was not for his stock. We agree with
respondent because respondent's position is more consistent with
both the stock redemption price stated in the 1973 agreement and
the value of CSB stock independent of that agreement.
Petitioner and respondent each called expert witnesses to
give their opinions about the value of decedent’s CSB stock.
Expert opinions can aid the Court in understanding an area
requiring specialized training, knowledge, or judgment. However,
as the trier of fact, the Court is not bound by the experts'
opinions. Helvering v. National Grocery Co., 304 U.S. 282, 295
(1938). The opinions of expert witnesses are weighed according
to their qualifications and other relevant evidence. Anderson v.
8(...continued)
follows:
CSB retained earnings $1,087,799
Present value of advanced client
costs 676,641
Insurance proceeds 5,000,000
6,764,440
Decedent’s 71.43 percent share 4,831,839
15-percent control premium 724,776
Value of decedent's CSB stock 5,556,615
9 We add $62,029 to that amount for premium adjustments and
interest which were not in dispute. See supra note 6.
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