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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 reflected
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