- 27 - 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 theirPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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