Estate of Frederick Carl Gloeckner, Deceased, Joseph A. Simone, and Douglas Dillon, Co-Executors - Page 21

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          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.           




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