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T.C. 312, 337 (1989) (quoting Estate of Curry v. United States,
706 F.2d 1424, 1429 (7th Cir. 1983)); see also Estate of Newhouse
v. Commissioner, 94 T.C. 193, 232 (1990). We are not persuaded
that buyers exist who would be willing to pay the value asserted
by Shapiro.
The experts’ selection of comparable companies with respect
to the market multiple estimates failed to consider objective
guideposts of comparability. In addition, petitioner’s experts
made extensive adjustments based on hindsight as to matters
occurring subsequent to the valuation date. Some of these
adjustments were based on interviews with petitioner’s employees
and representatives 10 years after the valuation date and in
anticipation of trial. Certain of the employees also testified
at trial. Their testimony was not corroborated by
contemporaneous records and thus appears to exaggerate 1989
adverse conditions and problems. The adjustments made were
inconsistent with assumptions used at the time of the
transaction. Such adjustments are susceptible to manipulation
for the purpose of achieving the result sought by the party, and
they are unreliable in this case. Shapiro, on the other hand,
did not sufficiently investigate the specific circumstances of
the company in 1989. Consequently, we do not rely completely on
the opinion of any of the experts and must do the best we can
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