- 33 -
Fuller relied on a single method, and we are not persuaded that
his method is the only one that would be considered by
hypothetical buyers and sellers. Kimball provided several
logical methods but failed to implement them correctly. On
cross-examination, he made several concessions about his use of
survey data as well as his errors in application of the formulas
he used.
We conclude that the discount claimed by petitioner is
necessarily overstated, but the discount asserted by respondent
is inadequate. Weighing the expert opinions and the evidence on
which they rely, we have more confidence in the methods of
petitioner's experts but must adjust their conclusions to reflect
their weaknesses. We bear in mind that valuation is necessarily
an approximation and a matter of judgment rather than
mathematics. Estate of Davis v. Commissioner, 110 T.C. 530, 554
(1998). Based on our examination of the entire record in this
case, we conclude that the marketability discount should be
25 percent. We thus have found that, on the valuation date, the
fair market value of each of the two 27.8671-percent interests in
FOH that were held by the trusts was $12,802,705, or $5.2031 per
share.
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