Estate of Richard R. Simplot - Page 34




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          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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