- 7 - v. Commissioner, T.C. Memo. 1997-53; sec. 20.2031-2(f)(2), Estate Tax Regs.; Rev. Rul. 59-60, 1959-1 C.B. 237, 238-239. Also, in valuing closely held corporations, discounts may be warranted to reflect the stock's lack of marketability and limitations on transferability. See Estate of Newhouse v. Commissioner, supra at 249; Estate of Andrews v. Commissioner, supra at 953; Estate of Brookshire, supra. We weigh expert witness testimony offered by the parties in light of particular facts and circumstances of each case. See Helvering v. National Grocery Co., 304 U.S. 282, 294-295 (1938); Seagate Tech., Inc. & Consol. Subs. v. Commissioner, 102 T.C. 149, 186 (1994); United Parcel Serv. of Am., Inc. v. Commissioner, T.C. Memo. 1999-268. Petitioner's first expert, using a 60-percent discount for lack of marketability, values the shares of decedent's stock in Hastings at $9,210,000, or $25.15 per share. Petitioner's first expert reached this opinion by: (1) Using the guideline company method of valuation and comparing Hastings to several publicly traded corporations engaged in similar lines of business; (2) using the guideline merged-and-acquired company method and comparing similar corporations that were bought or sold within a reasonable time of the valuation date; and (3) using the discounted cash-flow method. Due to alleged lack of independent bargaining and negotiations relating to the $47 price reflectedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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