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id. We may accept the opinion of an expert in its entirety, see
Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C.
441, 452 (1980), or we may be selective in the use of any portion
thereof, see Parker v. Commissioner, 86 T.C. 547, 562 (1986).
When valuing stock in the absence of arm’s-length sales, the
following factors are taken into consideration: The company’s
net worth, prospective earning power and dividend-paying
capacity, and other relevant factors. See sec. 25.2512-2(f),
Gift Tax Regs. The other relevant factors include:
the good will of the business; the economic outlook in
the particular industry; the company’s position in the
industry and its management; the degree of control of
the business represented by the block of stock to be
valued; and the values of securities of corporations
engaged in the same or similar lines of business which
are listed on a stock exchange. However, the weight to
be accorded such comparisons or any other evidentiary
factors considered in the determination of a value
depends upon the facts of each case. * * * [Id.]
Petitioner’s Expert
Petitioner presented the opinion of George H. Reddin of FMI
Corp., a management consulting firm to the construction industry
(petitioner’s expert). Petitioner’s expert valued IHC on a
minority interest basis at $2,161,467, or $340.93 per share.
Petitioner’s expert first valued IHC according to the cost
or asset approach. Beginning with the book value of IHC on
September 30, 1992, of $3,397,339, he made downward adjustments
for taxes ($138,005) and a “doubtful” account receivable
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