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Petitioners contend that, if we consider the redemption
price in 1995, then we should also consider the fact that MD&F
filed for bankruptcy protection in 1997. We need not do so
because we do not consider the 1995 redemption price.
3. Expert Witnesses
Both parties retained experts to testify in these cases.
Petitioners retained Management Planning, Inc. (MPI), to estimate
the value of Mr. DiSanto’s MD&F stock on November 26, 1992, as
part of a control block and minority block, and Mrs. DiSanto’s
“expectancy interest” in Mr. DiSanto’s estate (i.e., how much she
would expect to receive from his estate) on June 4, 1993.
Petitioners also retained William Harper Frazier (Frazier) to
estimate the value of Mrs. DiSanto’s estate’s “expectancy
interest” in Mr. DiSanto’s estate on June 4, 1993.
Respondent retained Herbert T. Spiro (Spiro), president of
American Valuation Group, Inc., as an expert witness. Spiro did
not appraise the MD&F stock. Rather, he critiqued the reports
prepared for petitioners by Deloitte & Touche and MPI and made
adjustments to them based on those critiques.
The following chart shows the values of a share of MD&F
stock as part of a control or minority block or an expectancy
interest in a share of MD&F stock as reported in the tax returns,
determined by respondent, contended by the parties, estimated by
petitioners’ experts, and adjusted by respondent’s expert in
critiquing petitioners’ experts in these cases:
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