- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011