- 36 -
In sum, we will consider expert opinion testimony to the
extent it assists our fair market value determination. Valuation
is an approximation, and the figure we reach need not be one as to
which there is specific testimony. Our role is to approximate fair
market value as closely as possible, within the range of figures
that may properly be deduced from the evidence. Silverman v.
Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo.
1974-285.
A. Valuations of Petitioner's Experts
1. The Weiksner Report
Petitioner's first expert, George B. Weiksner, is a managing
director and senior adviser of CS First Boston, an investment
banking firm. Mr. Weiksner has 25 years of investment banking
experience.
Mr. Weiksner's report valued the Trust's 49.04 percent
interest in JPMS common stock (1,226 shares) at $20,634,000 to
$25,489,000, with a midpoint value of $23,062,000. Mr. Weiksner's
report began with a comparable companies analysis13 that (1)
13 Comparable companies analysis is a public market
valuation tool that values a company by reference to publicly
traded companies with similar operating and financial
characteristics. The first step involves identifying appropriate
comparable companies and measuring their enterprise and equity
values as multiples of financial benchmarks. Mr. Weiksner
considered seven comparable companies.
The second step in the comparable companies analysis
involves applying the derived multiples to the corresponding
actual and projected financial benchmarks of the company subject
(continued...)
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