Estate of Frank M. DiSanto, Deceased, Roxanne DiSanto Tinnell, Byrnadette DiSanto, and Frank DiSanto, Coexecutors - Page 17




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          an expectancy interest in Mr. DiSanto’s estate because (a) no               
          shares had been transferred while she was alive,(b) Mr. DiSanto’s           
          estate could have sold some of those shares to pay administration           
          expenses, and (c) Mr. DiSanto gave her a residuary interest, not            
          stock.  We disagree.  There is no evidence that Mr. DiSanto’s               
          estate needed to sell MD&F stock to pay administration expenses.            
               2.   Value of MD&F Stock That Mrs. DiSanto Was Entitled To             
                    Receive Under Mr. DiSanto’s Will After Her 1993                   
                    Disclaimer                                                        
               We next decide whether to accept the values for MD&F stock             
          that Mrs. DiSanto was entitled to receive (which are lower than             
          those estimated for petitioners by Deloitte & Touche, MPI, and              
          Frazier) as contended by petitioners, or higher values, as                  
          contended by respondent.                                                    
               Petitioners contend that the Deloitte & Touche estimates are           
          unreliable because Braly was inexperienced and made errors in               
          Mrs. DiSanto’s estate tax return.  We disagree.  Braly relied on            
          Deloitte & Touche valuation experts to estimate the values of               
          assets to use in Mrs. DiSanto’s estate tax return.                          
               Petitioners contend that Mrs. DiSanto’s estate overestimated           
          the value of her interest in Mr. DiSanto’s estate.  We disagree.            
          There is no evidence that Deloitte & Touche made errors in                  
          appraising Mrs. DiSanto’s estate.  Deloitte & Touche’s and MPI’s            
          estimates are similar.                                                      
               MPI used the same general principles to appraise the value             
          of Mrs. DiSanto's interest in her husband's estate that it used             




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