- 6 - guided by our common sense, knowledge, and experience. Petitioner's frustration with our memorandum opinion is best attributed to its inability to build a better record from which we could have made a more precise determination. Petitioner chose to rely mainly on Mr. Chaffe to reach the end that it desired, and we found Mr. Chaffe's expertise to be of no important value.5 Accordingly, we decline to reconsider our memorandum opinion. To reflect the foregoing, An appropriate order will be issued denying petitioner's motion. 5 We also note that petitioner has never persuaded us that the shares were not marketable. Even assuming arguendo that the shares were not readily marketable, a fact that we were unable to find, we had trouble concluding on the instant record that the shares were not marketable at all. The marketability discount that we factored into the $50.50885 value set forth in our memorandum opinion at 1996-331 takes into account the absence of a recognized market for the subject stock, as well as the fact that a buyer may have to incur a subsequent expense to register the stock for public sale. See Mandelbaum v. Commissioner, supra; Estate of Trenchard v. Commissioner, T.C. Memo. 1995-121.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011