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Petitioner argues that a discount is warranted for the
"gloomy state" of the 1991 economy, Willits' past history of
economic loss, the absence of any real market for the shares, and
the extended holding period required to dispose of petitioner's
block. Only petitioner's last two assertions have any basis in
fact.
Willits' 1991 annual report to shareholders stated that it
"will show a sizeable increase in profits" even though the
"economy was such that the increase in deposits was very meager."
In fact, Willits showed a 15-percent increase in net income
compared to 1990. Thus, Willits appeared to be weathering the
gloomy state of the economy rather well.
Furthermore, petitioner's assertion that Willits has a
history of economic loss is not supported by the record. Mannon
testified that he thought Willits actually may have suffered a
negative income year in either 1981 or 1982, but that Willits
performed well in the late 1980's. We do not find Mannon's
testimony supports a finding that Willits has a history of loss,
and petitioner offered no other evidence to support this
assertion. Accordingly, we do not consider either of these
assertions in deciding the value of petitioner's shares.
Both sides submitted expert witness reports and presented
expert witness testimony in regard to the value of decedent's
shares of Willits stock at the date of death.
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