Estate of Emily F. Klauss - Page 6

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          selling prices for stock in a closely held corporation are not                
          available, then we decide its fair market value by considering                
          factors such as the company’s net worth, earning power, dividend-             
          paying capacity, management, goodwill, and position in the                    
          industry, as well as the economic outlook in its industry and the             
          values of publicly traded stock of comparable corporations.  See              
          Estate of Andrews v. Commissioner, 79 T.C. 938, 940 (1982); sec.              
          25.2512-2(f), Gift Tax Regs.                                                  
               Both parties called expert witnesses to give their opinions              
          about the value of decedent’s Green Light stock on February 1,                
          1993.  Bruce Johnson (Johnson) testified at trial for petitioner,             
          and David Fuller (Fuller) testified for respondent.  The record               
          also contains the expert report of Munroe, who could not testify              
          because of illness.  Petitioner based the value reported in the               
          estate tax return on Munroe’s appraisal, which is almost                      
          identical to petitioner’s position at trial.  The opinions of the             
          expert witnesses and the positions of the parties as to the fair              
          market value of decedent’s shares of Green Light stock are as                 
          Petitioner’s                        Deficiency                                
          return and     Petitioner’s         notice and      Respondent’s              
          the petition   expert Johnson       answer          expert Fuller             
          $1,810,000     $1,800,000           $4,080,200      $2,713,000                

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