Estate of Helen J. Smith, Deceased, Frederic L. Foill II and Cassandra F. Vallery, Co-Executors - Page 18




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               Court’s Analysis                                                       
               We found Mr. Hitt’s approach to be less useful than Mr.                
          Egan’s, largely because he did not provide as much detail from              
          which we could judge the merits of his reasoning.  Moreover, we             
          believe that his decision to give 75 percent of the weight to               
          earnings-based value and 25 percent to asset-based value was                
          incorrect, considering all the facts and circumstances of JFI.              
          As we noted earlier, “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.”  Estate of             
          Andrews v. Commissioner, 79 T.C. at 944.  Mr. Hitt’s choice of              
          weights ignores this principle.  Ultimately, however, we note               
          that by applying Mr. Egan’s weighting but otherwise accepting Mr.           
          Hitt’s report, we reach a result fairly close to the value of JFI           
          we have found to be correct.  Applying a weight of 70 percent to            
          Mr. Hitt’s asset-based value of $564 per share and 30 percent to            
          his earnings-based value of $243 per share results in a value of            
          $468 per share, a value much closer to the Court’s value of $439            
          per share than to the value proposed by respondent of $1,029 per            
          share.                                                                      
               Expert Opinion of Mr. Keath                                            
               In valuing the JFI stock, Mr. Keath calculated an asset-               
          based value only, because he believed that no part of the value             
          of JFI should be attributed to earnings.                                    






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