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inappropriately on companies that were not comparable to
Sterling. TWA, for example, had filed for bankruptcy on
January 31, 1992, and its auditor had expressed substantial doubt
concerning its ability to continue as a going concern. Sterling,
by contrast, was not in bankruptcy. Moreover, its 1990 through
1992 financial statements were accompanied by its auditor's
unqualified opinion on the validity of those statements. The
auditor did not conclude that Sterling was on the verge of
bankruptcy or that its future corporate existence was in doubt.
Likewise, Rymer's financial status resembled that of TWA. Rymer
had been told that its line of credit would not be renewed, which
raised serious concerns that, absent its recapitalization, it
would be driven into bankruptcy. Nothing in the record persuades
us that Sterling was on the verge of bankruptcy. To the
contrary, the record indicates that Sterling was a viable entity
that recapitalized primarily to alter its capital structure.
Finding no help from the only expert to testify on this
issue, we are left to value the decedent's Sterling preferred
stock based on the record at hand. We do not agree with
respondent that the redemption price of the Sterling preferred
stock equals its fair market value on September 18, 1992, a date
that preceded the redemption by 16 months. Sterling's mandatory
obligation to redeem the stock, however, does establish a
benchmark for determining the applicable value. We concluded
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