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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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