- 16 - the redemption. Petitioners’ argument continues as they explain that immediately after the redemption and subsequent stock distribution, the per-share value of RLIC’s stock was $93.14. Based upon this postredemption share price of $93.14, petitioners contend that the $176.13 per-share value reached in Chaffe’s report is reasonable because it accounts for growth in the amount of 89 percent. In contrast, petitioners argue, respondent’s determination of a $445 per-share value is unreasonable because it requires the acceptance of a growth rate of nearly 400 percent. Respondent argues that the redemption lacks probative value because of its remoteness to the 1988 stock transfer and because it involved family members. Because the redemption involved family members, respondent contends that it was not conducted at arm’s length. We are only partially convinced by petitioners’ argument as it requires the acceptance of a value derived from a transaction that occurred nearly 5 years earlier as the basis for establishing the accuracy of the result obtained in the Chaffe report. While we agree with petitioners that a recent arm’s-length sale of the subject property is probative of fair market value, we question whether and to what extent the remoteness of the redemption detracts from its probative worth. See Kaplan v. Commissioner, 43 T.C. 663, 665-666 (1965). We reject, however, respondent’s argument that the redemption lacksPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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