- 34 -
percent premium). In Wallace, a premium for voting shares was
calculated as a percentage of total equity value, rather than as a
percentage of nonvoting shares. Further, courts have found wide
disparities in value between voting and nonvoting shares, even
where the economic rights to dividends and liquidation proceeds do
not favor the voting shareholders. See Estate of Newhouse v.
Commissioner, 94 T.C. at 248-249 (each voting share worth
approximately $350,000 more per share than a nonvoting share even
though voting shareholders had no economic advantage in dividends
or liquidation).
Both parties relied upon experts' valuations in order to
demonstrate the correct value of the stock at issue. The
difference in amounts arrived at by the experts is extreme.
At times expert testimony aids the Court in determining
valuation; in other instances, it does not. See Laureys v.
Commissioner, 92 T.C. 101, 129 (1989). We weigh the testimony in
light of the expert's qualifications as well as other credible
evidence. See Estate of Christ v. Commissioner, 480 F.2d 171, 174
(9th Cir. 1973), affg. 54 T.C. 493 (1970). We have broad
discretion to evaluate "'the overall cogency of each expert's
analysis'". Sammons v. Commissioner, 838 F.2d 330, 333 (9th Cir.
1988) (quoting Ebben v. Commissioner, 783 F.2d 906, 909 (9th Cir.
1986), affg. in part and revg. in part on another issue T.C. Memo.
1983-200), affg. in part and revg. in part T.C. Memo. 1986-318. We
are not bound by the formulas and opinions offered by an expert,
especially when they are contrary to our judgment. See Estate of
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