Donald J. Janda - Page 12



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          and therefore assigned a zero percent.  As for the holding                  
          period, Mr. Wahlgren opined that neither the Company nor the Bank           
          would be sold within 10 years because Mr. Janda wanted to                   
          continue to operate the Bank for as long as possible and, in any            
          event, Robert Janda wanted to manage the bank thereafter.  With             
          regard to the holding period return of 21.47 percent, Mr.                   
          Wahlgren considered the risk-free yield on U.S. Treasury bonds,             
          the difference between long-term yields on common stock over                
          intermediate U.S. Government bonds, and a small stock premium.              
               Respondent challenges Mr. Wahlgren’s use of the QMDM model             
          on the basis that there is no evidence that appraisal                       
          professionals generally view the QMDM model as an acceptable                
          method for computing marketability discounts.  Respondent also              
          asserts that the data used by Mr. Wahlgren in the QMDM model is             
          inaccurate.                                                                 
               We recognized in Estate of Weinberg v. Commissioner, T.C.              
          Memo. 2000-51, that “slight variations in the assumptions used in           
          the [QMDM] model produce dramatic difference in results.”  The              
          effectiveness of this model therefore depends on the reliability            
          of the data input into the model.                                           
               We have serious reservations with regard to the assumptions            
          made by Mr. Wahlgren.  For example, we are concerned whether in             
          determining the growth rate of the Company, it was proper for Mr.           
          Wahlgren to simply average the Bank’s historical returns on                 
          equity for the 5 years prior to December 31, 1992, and then                 






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