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of its stock to be valued, and the amount and type of its
nonoperating assets if not considered elsewhere. Sec. 2031(b);
Estate of Andrews v. Commissioner, supra at 940; Estate of Hall
v. Commissioner, supra at 336; Duncan Indus., Inc. v.
Commissioner, supra at 276; sec. 20.2031-2(f), Estate Tax Regs.;
see also Mandelbaum v. Commissioner, T.C. Memo. 1995-255, affd.
without published opinion F.3d (3d Cir., June 10, 1996).
Respondent did not call an expert at trial to support her
determination that the value of the subject stock was $72.15 per
share on the Valuation Dates. Petitioner called its expert,
Mr. Chaffe, to support its asserted values, and the Court
received his expert report into evidence.10 See Rule 143(f).
Mr. Chaffe has been involved with the securities industry since
1959. His expert report consisted of: (1) The 1991 report,
(2) the 1989 report, (3) a consolidated balance sheet and income
statement of Eatel and its subsidiaries for the years 1984
through 1990 (with a column for “7/31/91 Annualized”), (4) a
one-page “Comparative Analysis”, which lists nine publicly traded
companies in the telephone or telecommunications industry, and
sets forth certain financial data with respect to each of them,
(5) five pages of Mr. Chaffe’s worksheets on the value of Eatel
as a single company, and (6) six pages of Mr. Chaffe’s worksheets
10 At the outset, we note that the expert report deals only
with the date-of-death value.
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