- 21 - competent to testify as to the value of his property, e.g., Juden v. Commissioner, T.C. Memo. 1987-302, affd. 865 F.2d 960 (8th Cir. 1989); Root v. Commissioner, T.C. Memo. 1981-330; O’Rourke v. Commissioner, T.C. Memo. 1981-279, Simone did not convince us that the prices set in the 1987 redemption agreement reflected adequate and full consideration. The weight to be given to the testimony of an owner of property as to the value of the property depends upon the owner’s knowledge, experience, method of valuation, and other relevant considerations. E.g., Root v. Commissioner, supra; O’Rourke v. Commissioner, supra. In 1987, Simone had less than a 1-percent ownership interest in the company, and that interest he obtained by gift. His testimony as to value was based, in part, on the 1987 appraisal, which is not in evidence as an expert witness report. Simone also stood to profit by a low estate tax valuation of the decedent’s shares. We accord no weight to Simone’s testimony as to what was adequate and full consideration in 1987. On January 4, 1988, the company redeemed all of Poesch’s common stock for $290 a share. That transaction occurred not long after decedent entered into the 1987 redemption agreement, and, for that reason, might be considered some evidence of whether the price to be paid for the decedent’s stock under the 1987 redemption agreement reflected adequate and full consideration in money or money’s worth as of the date of that agreement. See, e.g., Estate of Andrews v. Commissioner, 79 T.C.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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