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Specialty preferred stock. These values were accepted as filed
by respondent. Additionally, Cyril valued JM common stock at
$2.25 per share and JM preferred stock at $.90 per share in his
1949 gift tax return. Cyril’s 1949 gift tax return was not filed
until 1957, yet it acknowledged that the values it set forth were
in line with the stock values determined in connection with the
settlement of Joseph’s estate. We find the estate and gift tax
returns of Joseph and Cyril and the document setting forth the
agreed upon adjustments relating to Joseph’s estate tax return to
be persuasive in reaching our valuation decision. See, e.g.,
Estate of Hall v. Commissioner, 92 T.C. 312, 337-338 (1989);
Estate of Shafer v. Commissioner, supra at 1157. The values used
for estate and gift tax purposes for years contemporaneous to the
October 31, 1951, agreement generally support the valuation
report of Mr. Stewart and contradict the valuation report of Mr.
Browning.39
The valuation of the interests in issue is inherently more
difficult because they must be valued after nearly half a century
has passed and involve closely held companies devoid of stock
sales contemporaneous with the appropriate valuation date.
Valuation is necessarily an approximation, and a valuation
39The application of Cyril’s share ownership in JM and
Specialty to the 1949 to 1953 estate and gift tax value ranges of
$1.98 to $2.25 per share for JM common stock and $.90 to $1 per
share for JM preferred stock, and values of $1 per share for the
JM option stock, $150 per share for Specialty common stock, and
$.90 per share for Specialty preferred stock, yields approximate
valuation ranges of $206,000 to $232,000 for Cyril’s entire stock
interest, and $104,000 to $117,000 for his remainder interest.
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