- 6 - 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 receivablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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