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attributable to goods imported for retail sale. That issue is
quite important to a proper determination of the company’s value.
A sharp increase in retail sales of imported goods could cause a
sharp decrease in the company’s value, because the company only
sold products at the wholesale level.
Finally, Sherman did not take into consideration the 1988
sale by Poesch. The 1988 sale was at a discount, and we are
unable to determine at how much of a discount. See section IV,
supra. Nevertheless, we do not believe that the 1988 sale should
have been disregarded by Sherman.
For the above reasons, and considering the record as a
whole, we have found that the value of decedent’s shares on the
alternate valuation date was $4,000,000. We sustain respondent’s
determination of a deficiency to the extent consistent with our
findings.
Decision will be entered
under Rule 155.
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