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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
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 $2,713,000
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