Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas N.A., Independent Executor - Page 32

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               2.   Respondent's Expert:  Francis X. Burns                            
               Respondent relies on the expert report of Francis X. Burns,            
          a principal of IPC Group, LLC (IPC), a Chicago-based consulting             
          firm.  Mr. Burns, who holds a master of management degree in                
          finance and economics from Northwestern University's Kellogg                
          School of Management, valued Johnco based on the fair market                
          value of its assets.  Mr. Burns’ use of an asset approach is                
          supported by Rev. Rul. 59-60,21 1959-1 C.B. 237, 243, which                 
          states:                                                                     
               The value of the stock of a closely held                               
               investment or real estate holding company * * * is                     
               closely related to the value of the assets                             
               underlying the stock.  For companies of this type                      
               the appraiser should determine the fair market                         
               values of the assets of the company. * * *                             
          In support of his choice, Mr. Burns noted that Johnco:  (1) Was             
          classified as a personal holding company on its 1990 and 1991               
          returns; (2) had only one employee; and (3) produced no goods or            
          services other than the contracted sale of a percentage of timber           
          growth each year.  He also found it significant that petitioner             
          and respondent had stipulated the fair market value of Johnco's             
          assets.  Because the fair market value of the assets was                    
          stipulated, Mr. Burns' report focused on evaluating the merits of           
          petitioner's position regarding the valuation discounts it                  
          sought.                                                                     

               21 Rev. Rul. 59-60, 1959-1 C.B. 237, outlines factors to be            
          considered in valuing the stock of closely held corporations and            
          “has been widely accepted as setting forth the appropriate                  
          criteria to consider in determining fair market value”.  Estate             
          of Newhouse v. Commissioner, 94 T.C. 193, 217 (1990).                       

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