Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator - Page 27

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          companies.  They, therefore, turned to other methods of                     
          determining the value of the SOAI stock.                                    
               As we stated in Estate of Leyman v. Commissioner, 40 T.C.              
          100, 119 (1963), remanded on other grounds 344 F.2d 763 (6th Cir.           
          1965), in situations where it is difficult to find sales of                 
          comparable companies, consideration may be given to the value of            
          the underlying assets, the earnings, dividends paid, and numerous           
          other factors which would bear on a determination of value.  We             
          recognized there, as we do here, that the opinion of experts is             
          of assistance, but that even though we weigh the testimony of               
          experts in light of their qualifications as well as the other               
          credible evidence in the record, we are not bound by the opinion            
          of any expert witness and accept or reject expert testimony in              
          the exercise of sound judgment.  Estate of Newhouse v.                      
          Commissioner, 94 T.C. 193, 217 (1990).                                      
               Here, petitioner's experts gave great weight to the book               
          value of SOAI in arriving at the value of the stock transferred.            
          However, the record is clear that book value of an outdoor                  
          advertising company has very little relevance to the company's              
          fair market value, since it is the worth or market value of the             
          leases and billboards located thereon that creates the primary              
          asset value of the company.  These properties may have been                 
          acquired many years prior to the valuation date and been                    
          depreciated on the books even though an actual increase in value            
          had occurred.  Petitioner's experts attempt to back up their                




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