- 6 - 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 follows: 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 $2,713,000Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011