- 25 -
section 83 purposes must be determined as though the
restrictions did not exist. Sec. 83(b).
There 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 stock is determined by comparison
to the stock of similar companies with publicly traded
stock. Id. at par. 2.8. Under the income approach, the
value of stock is equal to the present value of the
company's future income stream. Id. at par. 2.9. Under
the cost approach, the value of stock is equal to the
fair market value of the company's assets less the total
amount of liabilities. Id. at par. 2.10.
We note that we are not bound by the methods or
opinions of any of the experts who testify at trial, but
may use their opinions to assist in determining the value
of the subject property. Chiu v. Commissioner, 84 T.C.
722, 734 (1985); Estate of Campbell v. Commissioner, T.C.
Memo. 1991-615. One expert may be persuasive on a
particular element of valuation, and another may be
persuasive on another element. Parker v. Commissioner,
86 T.C. 547, 562 (1986). Thus, we may adopt some aspects
Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 NextLast modified: May 25, 2011