- 19 - 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 hasPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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