Estate of James J. Renier, Deceased, Kent L. Renier and Dubuque Bank & Trust Company, Co-Executors - Page 7




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          appraisal, the estate reported decedent’s interest in Renier at a           
          value of $729,742, or $33.02 per share, on the valuation date.              
          In the notice of deficiency, respondent valued decedent’s                   
          interest in Renier at $1,633,000, or $73.89 per share, on the               
          valuation date.                                                             
                              ULTIMATE FINDING OF FACT                                
               The fair market value of decedent’s 22,100 shares of Renier            
          on the valuation date was $952,000, or $43.08 per share.                    
                                       OPINION                                        
          I.  Renier’s Fair Market Value                                              
               We must decide the fair market value of decedent’s shares of           
          stock in Renier on the valuation date.  Both parties rely on                
          expert opinions to support their claimed values.                            
               Fair market value is defined as “‘the price at which the               
          property would change hands between a willing buyer and a willing           
          seller, neither being under any compulsion to buy or to sell and            
          both having reasonable knowledge of relevant facts.’”  United               
          States v. Cartwright, 411 U.S. 546, 551 (1973)(quoting sec.                 
          20.2031-1(b), Estate Tax Regs.).  The best method to value a                
          corporation’s stock is to rely on actual arm’s-length sales of              
          the stock within a reasonable period of the valuation date.  See            
          Estate of Andrews v. Commissioner, 79 T.C. 938, 940 (1982).                 
          Since Renier’s stock was never publicly or privately traded, all            
          the experts used less direct methods of valuation.                          






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