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Rather, the weight to be given to each factor must be tailored to
account for the particular facts of each case. Messing v.
Commissioner, 48 T.C. 502, 512 (1967). This Court has recognized
that the valuation of stock in a closely held family corporation
is frequently a difficult question. Estate of McKitterick v.
Commissioner, 42 B.T.A. 130, 136 (1940); Estate of Tompkins v.
Commissioner, T.C. Memo 1961-338. We have also noted that the
result is rarely satisfactory. Estate of McKitterick v.
Commissioner, supra.
As is often the case when we are asked to resolve a
valuation dispute, the gap separating the instant parties is
substantial. Petitioners maintain that their original Federal
gift tax returns for 1988 overstate their gift tax liability due
to Willis’ erroneous appraisal of the 1988 stock transfer.
Petitioners, relying on Chaffe’s appraisal report, now argue that
the total value of the 1988 stock transfer was $536,844.24, or
$176.13 per share. Respondent, on the other hand, rejects
Chaffe’s report and maintains that the value of the 1988 stock
transfer amounted to $1,356,360, or $445 per share. Respondent’s
determination is based upon Willis’ method of appraisal; however,
her computation uses data obtained from RLIC’s 1988 financial
statements, rather than from the prior year’s financial
statements which were used by Willis. Respondent contends that
the financial data gathered from taxable year 1988 better reflect
RLIC’s value for purposes of the 1988 stock transfer. After a
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