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corporations. See sec. 20.2031-2(f), Estate Tax Regs. The fair
market value of stock is a question of fact. Hamm v.
Commissioner, 325 F.2d 934, 938 (8th Cir. 1963), affg. T.C. Memo.
1961-347.
Each party called expert witnesses to testify at trial.
They each valued petitioner’s Kosman, Inc., stock by valuing the
Scottsbluff National Corp. stock and Western National Bank stock
that Kosman, Inc., owned. We are not bound by the opinion of any
expert witness, and we may accept or reject expert testimony
exercising our sound judgment. Helvering v. National Grocery
Co., 304 U.S. 282, 295 (1938); Fitts' Estate v. Commissioner, 237
F.2d 729, 732-733 (8th Cir. 1956), affg. T.C. Memo. 1955-269;
IT&S of Iowa, Inc. v. Commissioner, 97 T.C. 496, 508 (1991).
Petitioner has the burden of proving that respondent's
determinations in the notice of deficiency are erroneous. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Respondent
has the burden of proving the increased deficiency asserted in
the amended answer. Rule 142(b).
2. Value of Kosman Inc.’s Scottsbluff National Corp. Stock
Petitioner's expert and respondent's experts concluded that
the value of Kosman, Inc.'s Scottsbluff National Corp. stock was
as follows:
Value Of Scottsbluff
Expert Valuation Date Natl. Corp. Stock
Petitioner’s 9/30/86 $2,810,133
Expert 3/31/87 2,991,447
Respondent's 9/30/86 4,633,555
Experts 3/31/87 4,633,555
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