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sold their shares to reach his conclusion of value.6 Mr. Tack
applied his primary valuation method, i.e., the discounted cash-
flow method, in a manner that is irreconcilable with our
understanding of that method. See Estate of Jung v.
Commissioner, 101 T.C. at 424 n.6.
We proceed to discuss in more detail some of the problems we
have with his reports. First, with respect to his analysis of
like public corporations engaged in the same or a similar line of
business, we do not find enough information on these corporations
to decide whether they are sufficiently similar to Seminole to
permit a proper valuation analysis, or whether another
corporation is better suited for this analysis. He tells us in
his initial report that several hundred companies in the business
of manufacturing uniforms have revenues under $10 million, that
approximately 30 such companies have revenues between $30 million
and $100 million, and that a few such companies have revenues in
excess of $100 million. Yet, he uses as his similar companies
for Seminole, a company the revenues of which were approximately
$47 million in 1993, six public corporations the revenues of
which for their taxable years ended on or near December 31, 1993,
ranged from a low of $130.5 million to a high of $505.7 million.
6 Upon redirect examination, Mr. Tack testified that he did
not take these sales into account. This testimony, however, is
contradicted by his initial report, which states specifically
that he did consider these sales. That report states: "These
transactions [the sales by Mr. Hoffman and Ms. Branch] were
consummated at the Merrill Lynch appraised value and have been
considered in our analysis."
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