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as capitalization of earnings or net asset values.
Certainly, the degree to which the corporation is
actively engaged in producing income rather than merely
holding property for investment should influence the
weight to be given to the values arrived at under the
different approaches but it should not dictate the use
of one approach to the exclusion of all others.
[Citations and fn. ref. omitted.]
It is clear that assets were the largest contributor to the value
of JFI. At the same time, since we are valuing shares in a
corporation rather than the assets themselves, the corporation’s
status as an operating business must be taken into account, which
is accomplished by considering income-based indicators of value.
See id. at 946. However, as we said in Estate of Andrews v.
Commissioner, supra at 944: “the value of the underlying real
estate will retain most of its inherent value even if the
corporation is not efficient in securing a stream of * * *
income.” We believe that Mr. Egan properly considered all of
these factors in giving 70 percent of the weight to asset-based
value and 30 percent to earnings-based value.
Respondent’s primary dispute with Mr. Egan’s, and more
broadly petitioner’s, approach to valuing JFI is the fact that
Mr. Egan gave some weight to earnings-based value, whereas
respondent believes the value of JFI should be based solely on
its assets. Respondent argues that the disparity between the
asset-based and earnings-based values demonstrates that only an
asset-based value should be used. This argument is unpersuasive
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