Estate of Artemus D. Davis, Deceased, Robert D. Davis, Personal Representative - Page 11

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          2(f), Gift Tax Regs.  As the trier of fact, we have broad                   
          discretion in assigning the weight to accord to the various                 
          factors and in selecting the method of valuation.  Estate of                
          O'Connell v. Commissioner, 640 F.2d 249, 251-252 (9th Cir. 1981),           
          affg. on this issue and revg. in part T.C. Memo. 1978-191; sec.             
          25.2512-2(f), Gift Tax Regs.                                                
               The determination of the value of closely held stock, like             
          each of the two 25-share blocks of ADDI&C stock at issue, is a              
          matter of judgment, rather than of mathematics.  Hamm v.                    
          Commissioner, 325 F.2d 934, 940 (8th Cir. 1963), affg. T.C. Memo.           
          1961-347.  Moreover, since valuation is necessarily an                      
          approximation, it is not required that the value that we determine          
          be one as to which there is specific testimony, provided that it            
          is within the range of figures that properly may be deduced from            
          the evidence.  Silverman v. Commissioner, 538 F.2d 927, 933 (2d             
          Cir. 1976), affg. T.C. Memo. 1974-285; Anderson v. Commissioner,            
          250 F.2d 242, 249 (5th Cir. 1957), affg. in part and remanding in           
          part T.C. Memo. 1956-178.                                                   
               As is customary in valuation cases, the parties rely                   
          extensively on the opinions of their respective experts to support          
          their differing views about the fair market value on the valuation          
          date of each of the two 25-share blocks of ADDI&C stock in                  
          question.  The estate relies on (1) Mr. Howard, who is an                   
          accredited senior appraiser of the American Society of Appraisers           
          and a principal in the business valuation firm of Howard Frazier            




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