- 39 -
Although expert opinions can assist the Court in evaluating a claim,
we are not bound by the opinion of any expert and may reach a
decision based on our own analysis of all the evidence in the
record. Helvering v. National Grocery Co., 304 U.S. 282, 295
(1938); International Multifoods Corp. v. Commissioner, 108 T.C. 25,
46-47 (1997). Questions of value are an inherently imprecise
exercise. Messing v. Commissioner, 48 T.C. 502, 512 (1967); Estate
of Lauder v. Commissioner, supra.
Petitioners rely upon the expert reports and testimony of
Matthew G. Kimmel, a national director in the Chicago, Illinois,
office of Arthur Andersen's Valuation Services Group. Mr. Kimmel is
a licensed realtor in the State of Indiana and a certified general
real estate appraiser in several States.
In the instant case, Mr. Kimmel relied upon the income and cost
approaches in determining CamVic's fair market value in 1975 and
1981.28 In his report which was introduced at trial, Mr. Kimmel
28There are three generally accepted methods of determining
the value of stock: The market comparison approach, the income
approach, and the cost approach. Fishman, "Valuation Termination
and Methodology", in Financial Valuation: Businesses and
Business Interests, par. 2.7 (Zukin ed. 1990). Under the market
comparison approach, the value of a company's stock is determined
by comparison to the stock of similar companies with publicly
traded stock. Under the cost (or asset-based) approach, the
value of stock is equal to the fair market value of the company's
assets less the total amount of its liabilities. Finally, under
the income approach, the value of stock is equal to the present
value of a company's future income stream. See id. pars. 2.7-
2.10; see also Morton v. Commissioner, T.C. Memo. 1997-166. With
respect to the market approach, Mr. Kimmel's report stated that
it was considered but not relied upon in the determination of
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