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were sold in 1985, and a 1986 gift tax return reports that a
corporate competitor of DATA had offered to buy a former
shareholder’s minority interest in DATA (approximately 23.8
percent) at a premium in 1985. We also note that Eatel’s
21 shareholders in 1989 grew to approximately 30 on the Valuation
Dates.
Although we reject Mr. Chaffe’s opinion in full, we do not
believe that the value of the subject stock was $72.15 on both
dates, as respondent determined. We find incredible that the
4-percent discount reflected in the notice of deficiency
adequately accounts for both a marketability and minority
discount, as well as the change in the setting from the date of
the redemption agreement to the date of Decedent’s death. We
proceed to determine the value of the stock on the Valuation
Dates. The record does not allow us to make a precise
determination of the stock’s values; thus, we rely on our common
sense, knowledge, and experience to help us ascertain these
values. Valuation, which is simply an approximation, is
inherently imprecise and usually capable of resolution only by a
Solomon-like pronouncement. Anderson v. Commissioner, 250 F.2d
242, 249 (5th Cir. 1957), affg. in part and remanding in part
T.C. Memo. 1956-178; Phillips Petroleum Co. v. Commissioner,
104 T.C. 256, 309 (1995); Messing v. Commissioner, 48 T.C. 502,
512 (1967).
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