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considered depending upon the facts and circumstances of each
case. See also Estate of Andrews v. Commissioner, 79 T.C. at
940; Messing v. Commissioner, 48 T.C. at 512. It follows that
the facts and circumstances of a particular case may be such that
an appraiser accords no weight to such share prices.
Accordingly, petitioners’ argument in this regard is misplaced.
We are also troubled by respondent’s argument that the
discounted per-share value of the 1988 stock transfer was $445.
Although we agree with respondent that it makes more sense to
value a gift of stock made in December 1988 using financial data
as of December 31, 1988, rather than December 31, 1987, we
question whether the computation respondent used to perform such
valuation was appropriate. See Symington v. Commissioner, 87
T.C. at 896. In addressing this matter we focus our attention on
Willis, as it was he who created the model used by respondent to
ascertain the discounted per-share value of the 1988 stock
transfer. We recognize that Willis has respectable credentials,
but we are troubled by his unfamiliarity with relevant Treasury
regulations and revenue rulings. While such unfamiliarity does
not in and of itself convince us that Willis was incapable of
rendering an accurate valuation, it does raise some suspicion.
We also question the accuracy of his appraisal in light of his
testimony regarding two variables used in his computation: The
minority interest discount and the annual premium increase. With
respect to the annual premium increase, Willis testified that he
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