- 36 -
(c) The book value of the stock and the financial
condition of the business.
(d) The earning capacity of the company.
(e) The dividend-paying capacity.
(f) Whether or not the enterprise has goodwill or
other intangible value.
(g) Sales of the stock and the size of the block of
stock to be valued.
(h) The market price of stocks of corporations
engaged in the same or a similar line of business
having their stocks actively traded in a free and open
market, either on an exchange or over-the-counter.
[Rev. Rul. 59-60, 1959-1 C.B. at 238-239.]
As is customary in valuation cases, the parties rely
primarily on expert opinion evidence to support their contrary
valuation positions. We evaluate the opinions of experts in
light of the demonstrated qualifications of each expert and all
other evidence in the record. See Anderson v. Commissioner,
supra; Parker v. Commissioner, 86 T.C. 547, 561 (1986). We have
broad discretion to evaluate "'the overall cogency of each
expert's analysis.'" Sammons v. Commissioner, 838 F.2d 330, 334
(9th Cir. 1988) (quoting Ebben v. Commissioner, 783 F.2d 906, 909
(9th Cir. 1986), affg. in part and revg. in part T.C. Memo. 1983-
200), affg. in part and revg. in part on another ground T.C.
Memo. 1986-318. Expert testimony sometimes aids the Court in
determining values; sometimes it does not, particularly when the
expert is merely an advocate for the position argued by one of
the parties. See, e.g., Estate of Halas v. Commissioner, 94 T.C.
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