Estate of Frank M. DiSanto, Deceased, Roxanne DiSanto Tinnell, Byrnadette DiSanto, and Frank DiSanto, Coexecutors - Page 13




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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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