- 10 -
Both of petitioner's experts opined that a control premium
should not be applied to decedent's block of 201,408 shares
because they believed that the shares (representing 23.8 percent
of the stock in Wilber Corp) did not constitute a controlling
interest. Based on their valuations and on their analyses with
respect to the number of shares to be valued, petitioner's
experts concluded that, as of October 20, 1990, the value of the
201,408 shares of Wilber Corp's stock that were owned by decedent
at the time of his death was $7,653,504, or $38 per share.
Respondent's expert relied primarily on a market transaction
approach to valuation in concluding that, as of October 20, 1990,
the value of decedent's shares of stock in Wilber Corp was
$13,562,815, or $67.34 per share. Respondent's expert
acknowledged that, in October of 1990, the economy was in a
recession and that in the Northeast region the economy was
experiencing a particular downturn due to financial difficulties
of its two primary industries, defense and finance.
With respect, however, specifically to the Oneonta, New York
region, respondent's expert concluded that the region (because it
was more rural and less tied to the defense and finance
industries) was less likely to be affected by general economic
difficulties of the Nation and of the Northeast region.
Respondent's expert concluded that petitioner's experts'
valuations of the shares of stock in Wilber Corp were
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011