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must hold the subject stock to realize a sufficient profit;
(9) the corporation's redemption policy; and (10) the cost of
effecting a public offering of the stock to be valued; e.g.,
legal, accounting, and underwriting fees. Mandelbaum v.
Commissioner, supra.
Each party called a witness whom they and he asserted was an
expert on valuation and would help the Court determine the fair
market value of the estate's stock. Petitioners called Bret
Tack, accredited senior appraiser, a principal of the firm of
Houlihan Valuation Advisors. Mr. Tack graduated from college in
1985, and he has continued to work in the valuation field ever
since. We recognized Mr. Tack as an expert on business
valuation, and we accepted his reports into evidence. His
initial report analyzed the fair market value of the estate's
stock as of April 14, 1994, concluding that the estate's stock
interest was a minority, noncontrolling interest that had a fair
market value on that date of $30.85 per share. He reached his
conclusion after analyzing two of the three relevant valuation
methods; namely, the market comparative method and the discounted
cash-flow method. He did not analyze the third method; i.e., the
net asset value method. His supplemental report discussed the
marketability discount in the setting of the Mandelbaum factors,
concluding that the 35-percent discount factored into his $30.85
per-share value was consistent with a Mandelbaum analysis.
Respondent called William K. Fowler, A.M., a financial
analyst employed by the Internal Revenue Service. Mr. Fowler has
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