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Neither side has convinced us that its computation of the
per-share stock price accurately reflects the true value of the
stock transfer at issue, but petitioners have advanced the more
convincing argument. With respect to petitioners’ argument,
however, we note that it is not without its shortcomings.
Although we may choose to accept Chaffe’s appraisal in its
entirety, Buffalo Tool & Die Manufacturing Co. v. Commissioner,
74 T.C. 441, 452 (1980), we may also be selective in the use of
any portion of such appraisal, Parker v. Commissioner, 86 T.C.
547, 562 (1986). We are particularly troubled by the brevity of
Chaffe’s report. Specifically, Chaffe’s report does not provide
a discussion of the computation or model used to derive the
discounted per-share value of $176.13. Furthermore, in his
report, Chaffe explains that he considered a variety of factors,
but he does not elaborate to any significant degree as to what
effect such consideration had on any particular variable involved
in his computations. Similarly, Chaffe explains in his report
that he considered the stock value of several publicly traded
insurance corporations, but he failed to provide any explanation
of how such share values influenced his calculations. We are
similarly troubled by the financial dissimilarities between RLIC
and the publicly traded firms used as comparables by Chaffe in
his report. For example, the average premium income for the five
comparable firms used in Chaffe’s analysis was $150,020,000;
RLIC’s premium income in 1988 amounted to $2,406,000. Similarly,
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