- 11 - Respondent argues that neither Rev. Rul. 59-60, supra, nor section 25.2512-2(f), Gift Tax Regs., requires that stock prices of publicly traded companies be considered when valuing the stock of a closely held corporation. Rather, respondent maintains, consultation of such stock prices is unnecessary if alternative appropriate means of valuation are available. Respondent contends that Willis’ credentials and experience in the insurance industry enabled him to prepare his appraisal without considering stock prices of publicly traded companies. Particularly, respondent maintains that Willis’ appraisal was benefited by Willis’ “intimate familiarity” with the sale of industrial life insurance companies located in Louisiana. In support of this contention, respondent explains that Willis had completed an appraisal, similar to the one in the instant case, for an industrial life insurance firm located in Arkansas immediately prior to being hired by David Rabenhorst to prepare the appraisal involved in the instant case. In contrast, respondent’s argument continues, Chaffe’s report lacks the benefit of such professional experience. In fact, respondent explains, prior to preparing the instant appraisal, Chaffe had never before prepared an appraisal valuation of an industrial life insurance firm. Respondent also explains that Chaffe’s report is inherently flawed because of the dissimilarities between RLIC and the publicly traded life insurance companies used as comparables in his report.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011