- 12 - his weighted value for JFI, Mr. Egan estimated the value of JFI to be $439 per share ($675 per share less 35 percent). Thus, according to Mr. Egan, the fair market value of decedent’s interest in JFI was $85,605 (195 shares x $439 per share). Court’s Analysis We find Mr. Egan’s report to be very persuasive and well supported by his underlying reasoning. We conclude, largely on the basis of Mr. Egan’s report, that the fair market value of decedent’s interest in JFI was $439 per share on the date of her death. Mr. Keath’s report, the only support for the substantially higher value determined by respondent, was seriously flawed and unpersuasive. It is well established that, in general, an asset-based method of valuation applies in the case of corporations that are essentially holding corporations, while an earnings-based method applies for corporations that are going concerns. See Estate of Ford v. Commissioner, T.C. Memo. 1993-580, affd. 53 F.3d 924 (8th Cir. 1995). JFI has characteristics of both, given the significance of real property in a farming operation, and we find that it is appropriate to consider both asset- and earnings-based values. As we said in Estate of Andrews v. Commissioner, 79 T.C. at 945: regardless of whether the corporation is seen as primarily an operating company, as opposed to an investment company, courts should not restrict consideration to only one approach to valuation, suchPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011