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the market approach is based on trading done by minority
stockholders. Mr. Browning testified that he applied a minority
discount in this situation because if he did not then his market
approach generally yielded a value higher than the value
determined under his DCF approach. We do not find Mr. Browning’s
explanation for applying a minority discount in this situation to
be satisfactory because it is not based on valuation standards,
but rather on the fact that he is adjusting his valuation simply
to yield a result closer to that produced under his DCF approach.
The value of the consideration received by Cyril was
determined in the notice of deficiency to be $43,878. This
determination is entitled to the presumption of correctness. See
Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933); Estate
of Magnin v. Commissioner, 184 F.3d at 1081; Estate of Jung v.
Commissioner, 101 T.C. 412, 423 (1993). In order to overcome the
presumption, the estate must introduce some substantial evidence
which shows that respondent was wrong. See Rockwell v.
Commissioner, 512 F.2d 882, 885 (9th Cir. 1975), affg. T.C. Memo.
1972-133; Estate of Gilford v. Commissioner, 88 T.C. 38, 51
(1987). The burden of showing that the valuation determinations
in the notice of deficiency are incorrect “is a burden of
persuasion; it requires * * * [the estate] to show the merits of
* * * [its] claim by at least a preponderance of the evidence.”
Rockwell v. Commissioner, supra at 885; Estate of Gilford v.
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