- 32 - 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).Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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