- 52 - Commissioner, supra at 51; see also Estate of Simplot v. Commissioner, 112 T.C. at 149-150. The estate’s valuations of the interests transferred and received by Cyril contain errors under both a hypothetical standard and an actual standard. These errors cast doubt on the estate’s overall valuation of the interests in issue, and we accord little weight to the estate’s valuations in reaching our decision. Accordingly, the estate has failed to carry its burden of establishing that the value of the consideration received by Cyril was different from the value determined in the notice of deficiency. Respondent bears the burden of proving any increases in the deficiency asserted in the amended answer (i.e., that the consideration received by Cyril was less than $43,878). See Rule 142(a); Estate of Bowers v. Commissioner, 94 T.C. 582, 595 (1990). Respondent presented evidence and testimony in support of the position that the value of the consideration was approximately $30,500. Respondent partially relied on Mr. Stewart’s DCF analysis in valuing the interests at issue. After trial, Mr. Stewart corrected his error of not subtracting projected capital expenditures in his original report, but it is troubling that such a large mistake was made in the first place. Also, Mr. Stewart used a valuation date of January 31, 1952, instead of October 31, 1951, because he claims that he would have had to rely on information that was 9 months old. While eventsPage: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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