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offers were for all of Eatel’s stock, whereas the issue at hand
concerns minority interests; (3) Eatel’s 1992 earnings per share
increased by more than 27.9 percent over its 1990 earnings per
share and by more than 19.95 percent over its 1991 earnings per
share; (4) petitioner's expert concluded that the price-earnings
multiples of comparable publicly traded telecommunications
corporations increased by more than 50 percent between the date
of Decedent’s death and March 1993; and (5) petitioner's expert
concluded that the premiums paid in 1993 for the stock of
publicly traded telecommunications corporations were more than
52 percent above the prices at which minority blocks were then
trading.
We disagree with petitioner that the disputed evidence is
irrelevant to our determination herein. Federal law favors the
admission of evidence, and the test of relevancy under Federal
law is designed to reach that end. Rule 401 of the Federal Rules
of Evidence, a rule that applies to this Court under Rule 143(a),
Tax Court Rules of Practice and Procedure, provides broadly that
evidence is “relevant" if it has “any tendency to make the
existence of any fact that is of consequence to the determination
of the action more probable or less probable than it would be
without the evidence.” Rule 401 of the Federal Rules of Evidence
favors a finding of relevance, and only minimal logical relevancy
is necessary if the disputed fact’s existence is of consequence
to the determination of the action. Daubert v. Merrell Dow
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