- 30 - the stock". Estate of Andrews v. Commissioner, 79 T.C. 938, 956 (1982). Petitioner must prove that respondent's determination of value set forth in her notice of deficiency is incorrect. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933); Estate of Gilford v. Commissioner, 88 T.C. 38, 51 (1987). Respondent bears the burden of proving the increases in the deficiency asserted in her amended answer. Rule 142(a); Estate of Bowers v. Commissioner, 94 T.C. 582, 595 (1990). Valuation is a question of fact, and the trier of fact must weigh all relevant evidence to draw the appropriate inferences. Hamm v. Commissioner, 325 F.2d 934, 938 (8th Cir. 1963), affg. T.C. Memo. 1961-347; Estate of Newhouse v. Commissioner, supra at 217. After considering the reports and testimony of both experts and all the other evidence in the record, we think that neither party has shown that the value of the interest received by Cyril should be greater or less than the $43,878 determined by respondent in her notice of deficiency. Accordingly, we hold that petitioner is entitled to reduce the includable value of the trusts by $43,878 pursuant to section 2043(a). The final issue for decision concerns the fair market value of a retail shoe store located in Louisville, Kentucky, as of December 8, 1988, the alternate valuation date. Petitioner valued the property at $150,980 on its estate tax return. In the notice of deficiency, respondent valued the property atPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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