- 18 - 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.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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