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depth and trend as a whole (measured at and after the valuation
date). See, e.g., Estate of Christie v. Commissioner, supra.
With the foregoing in mind, the stage is now set for our
consideration of the expert opinions offered by each of the parties
in support of their respective positions as to the blockage
discount to be herein applied.
Petitioner's Expert
Mr. Kleeman (the individual who wrote a July 1997 report
discussed supra p. 15) was petitioner's expert witness. He has an
undergraduate degree in accounting, is a licensed certified public
accountant, and heads the business valuation practice of the
accounting firm of Clifton Gunderson, L.L.C. At the time of trial,
he held three business valuation designations (one each from the
American Institute of Certified Public Accountants, the American
Society of Appraisers, and the National Association of Certified
Valuation Analysts).
Practically all of the 60 to 80 business valuation assignments
Mr. Kleeman prepares or reviews every year consist of valuations
concerning closely held companies. In addition to the work he
performed for petitioner, Mr. Kleeman participated in a few other
assignments involving the application of the blockage discount in
determining the value of publicly traded stock.
Mr. Kleeman prepared his September 1998 report for purposes of
this trial. He therein concluded that a 22.5-percent blockage
discount was appropriate in valuing the stock at issue, resulting
in a valuation of $11.72 per share or total of $3,288,000 for all
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