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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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