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is the mean between the highest and lowest selling prices on the
valuation date. Sec. 20.2031-2(b)(1), Estate Tax Regs. A
blockage discount may, however, be applied when the block of
stock to be valued is so large that it cannot be liquidated in a
reasonable time without depressing the market. Sec. 20.2031-
2(e), Estate Tax Regs. The concept of blockage is essentially
one of timing. See Estate of Smith v. Commissioner, 57 T.C. 650,
657-658 (1972), affd. 510 F.2d 479 (2d Cir. 1975).
Petitioner has the burden of proof as to the correctness and
amount of the discount. Rule 142(a); Estate of Van Horne v.
Commissioner, 720 F.2d 1114, 1117 (9th Cir. 1983), affg. 78 T.C.
728 (1982). This burden is a burden of persuasion, requiring
petitioner to prove the merits of its claim by at least a
preponderance of the evidence. Rockwell v. Commissioner, 512
F.2d 882, 885 (9th Cir. 1975), affg. T.C. Memo. 1972-133;
Brumley-Donaldson Co. v. Commissioner, 443 F.2d 501, 504 n.4 (9th
Cir. 1971), affg. T.C. Memo. 1969-183.
Both parties rely extensively on expert testimony to
establish the amount of the discount. Expert opinions are
admissible if they will assist the trier of fact to understand
evidence that will determine a fact in issue. Fed. R. Evid. 702.
We evaluate the opinions of experts in light of the demonstrated
qualifications of each expert and all other evidence in the
record. Parker v. Commissioner, 86 T.C. 547, 561 (1986).
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