- 23 - reflected adequate and full consideration in money or money’s worth as of the date of execution of the agreement. V. Fair Market Value of Decedent’s Shares Disregarding the 1987 redemption agreement, we must determine the fair market value of decedent’s shares on the alternative valuation date. We discount much of Simone’s testimony for reasons similar to those previously stated. Respondent has conceded that the value of decedent’s shares is no greater than $4,580,000. We accept that concession and also find Sherman’s opinion to be helpful in determining the fair market value of decedent’s shares. We do not, however, completely agree with Sherman because we find some weaknesses in his analysis of the value of decedent’s shares. First, Sherman did not make an on-site inspection of the company or interview the company’s management. Second, he could find no comparable companies on which to base his valuation. Third, we believe that Sherman did not adequately consider the effect of competition on the company’s value. The company sold in the wholesale market. The company was in a poor competitive position vis-a-vis its domestic competitors, some of which were vertically integrated. In addition, Sherman did not adequately analyze the impact of international competition on the company’s value. In analyzing the conditions in the horticultural industry, Sherman only analyzed retail sales figures. Sherman, however, made no effort to determine the extent to which the growth in the horticultural industry’s retail sales wasPage: 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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