-8-
Inc., was in turn engaged by Mr. Aughtry to prepare an appraisal
of the shares of the Company for use in the gift tax valuation
cases of Mr. Thompson and petitioner.
Mr. Mercer prepared an appraisal report and submitted it to
Mr. Thompson. Mr. Mercer's fee was paid by the Company and
charged as compensation to Mr. Thompson.8 Although Mr. Aughtry
and Mr. Mercer were formally engaged by Mr. Thompson, it was
understood that they would also represent petitioner's interests
in her separate gift tax case. Mr. Aughtry entered his
appearance in petitioner's case on March 15, 1994.
Petitioner provided a copy of the valuation report prepared
by Mr. Mercer to respondent within the time required under Rule
143(f). Respondent, on the record at a hearing in Atlanta,
Georgia, on April 22, 1994, accepted the per-share value of the
Company stock as determined by Mr. Mercer, $124.50 for the year
1988, and lesser values for gifts in the 2 previous years.
Respondent also conceded on the record that the addition to tax
under section 6660 would not apply. It was agreed that the
settlement would apply to both petitioner's and Mr. Thompson's
case. Since Mr. Thompson had a net worth in excess of
$2 million, he did not file a motion for fees and costs in his
case.
8The Company advanced other litigation costs and charged
them as compensation to Mr. Thompson.
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