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We are convinced that the valuation issue is capable of
resolution by the parties themselves through an
agreement which will reflect a compromise Solomon-like
adjustment, thereby saving the expenditure of time,
effort, and money by the parties and the Court--a
process not likely to produce a better result. Indeed,
each of the parties should keep in mind that, in the
final analysis, the Court may find the evidence of
valuation by one of the parties sufficiently more
convincing than that of the other party, so that the
final result will produce a significant financial
defeat for one or the other, rather than a middle-of-
the-road compromise which we suspect each of the
parties expects the Court to reach. * * * [Id. at 451-
452; citations omitted.]
Of course, because the parties have insisted that we value the
Demco stock, we shall do our job.
For the reasons set forth below, we conclude petitioners
have not shown that the value of the gifts was less than the
$260.13 per share respondent determined in the statutory notices.
To the contrary, the record persuades us that the value was at
least equal to that amount.
In reaching this conclusion, we are not imposing a sanction
on petitioners, cf. the taxpayer’s argument in Estate of Kaplin
v. Commissioner, 748 F.2d 1109, 1111-1112 (6th Cir. 1984), revg.
on another ground T.C. Memo. 1982-440, nor should Buffalo Tool &
Die be interpreted as expressing an intention to do so in any
comparable circumstances. See Parker v. Commissioner, 86 T.C.
547, 562 (1986). We have merely found respondent’s original
determination in the statutory notices to be closer to the actual
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