- 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.
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