- 14 -
One Share in–
A control A minority A minority An expectancy
block on block on block on Interest on
Source Nov. 26, 1992 Nov. 26, 1992 June 4, 1993 June 4, 1993
Deloitte & $25.80 $15.53
Touche
P's Tax $25.80 $15.53
Returns
Notice of $52.50 $52.50
Deficiency
MPI $23.50 $14.96 $13.00 $9.00
Frazier $13.00 1$3.67
Spiro’s $27.72 $25.50
critique of
Deloitte &
Touche
Spiro’s $26.28 - $15.03 - $13.32 -
critique of $30.35 $17.36 $14.76
MPI
P's posttrial $12.16 $2.22 – if it
brief were 121,823
shares
R's posttrial $30.00 $16.00 $14.00
brief
1 Frazier estimated that the total value of Mrs. DiSanto’s estate’s
interest in Mr. DiSanto’s estate was $447,327. He did not estimate a per
share value based on 121,823 shares as did the other experts. The $3.67
amount represents a per share value based on 121,823 shares with a total value
of $447,323.
4. Evaluating the Experts’ Opinions
We are not bound by the opinion of any expert, and we may
accept or reject expert testimony in the exercise of sound
judgment. See Phillips Petroleum Co. v. Commissioner, 104 T.C.
256, 302 (1995); Estate of Hall v. Commissioner, 92 T.C. 312, 338
(1989).
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