- 4 - appraisals, neither of which is in the record and neither of which included a marketability discount. Respondent determined that the Decedent’s CGT stock was worth $15,440,000 on the alternate valuation date. The parties have since stipulated that the June 11, 1990, value of the Decedent’s CGT stock was $12,250,000, without regard to any marketability discount or control premium that may otherwise apply. The parties’ stipulation followed their receipt of appraisals of the stock’s value as of June 11, 1990. Respondent’s sole appraisal stated that the stock was worth $12,619,000. Petitioner’s three appraisals stated that the stock was worth $11,625,000, $11,652,555 and $11,850,000, respectively. In making these appraisals, all of the appraisers relied primarily upon transactional and financial data compiled by Paul Kagan Associates, Inc. (Kagan), and none of the appraisers determined CGT’s value by reference to the price of stock that was listed on a public exchange. The transactions reported by Kagan included recent transactions in which stock of television stations was transferred at arm's length. All of the appraisers also considered the nature of CGT, its history, its position in the industry, its economic outlook, and other factors listed in Rev. Rul. 59-60, 1959-1 C.B. 237 (regarding the valuation of stock for Federal estate tax purposes).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011