-20- year period before the date of each gift), and the formulas described in Estate of Feldmar v. Commissioner, T.C. Memo. 1988- 429. He multiplied Crossroads' pretax weighted average income by a price/earnings capitalization rate of five to estimate the value for the stock. Wise calculated Crossroads' average claim paid to show whether it had enough reserves to pay its historical claims. He projected that the price/earnings value of Crossroads' stock (using weighted average earnings) was $978 per share as of January 1, 1992, and $1,537 per share as of January 1, 1993. He weighted the price/earnings method 60 percent and the book value method 40 percent to estimate the value of Crossroads' stock on the gift dates. He estimated that Crossroads' stock was worth $1,083 per share as of January 1, 1992, and $1,554 per share as of January 1, 1993. He then applied a 35-percent discount and estimated that the stock was worth $704 per share as of January 1, 1992, and $1,010 per share as of January 1, 1993. C. Analysis We accept KPMG Peat Marwick's reserve estimate and appraisal of Crossroads' common stock instead of those of Gallagher or Wise. 1. KPMG Peat Marwick Respondent points out that Crossroads did not discount its 1991 and 1992 reserves for the time value of money, and contendsPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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