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Charles A. Wilhoite (Wilhoite) presented expert testimony on
behalf of respondent. Wilhoite, a certified public accountant,
is a principal of Willamette Management Associates and codirector
of that firm’s office in Portland, Oregon. He has performed a
number of assignments involving the analysis and appraisal of
professional practices, with a heavy concentration in the health
care field. He has been involved with assignments requiring the
valuation of intangible assets, including CONs, customer
relationships, goodwill, and workforces.
Petitioners argue that Wilhoite’s testimony should be
stricken because, they claim, his qualifications as an expert and
his methodology are insufficient to meet the standards set forth
in Daubert v. Merrill Dow Pharm., Inc., 509 U.S. 579 (1993).
These contentions are nonsensical and border on the frivolous.
Gross v. Commissioner, T.C. Memo. 1999-254, affd. 272 F.3d 333
(6th Cir. 2001). We have no reason to question our recognition
of Wilhoite as an expert on the fair market valuation of health
industry and related businesses; i.e., the business of the
Sta-Home tax-exempt entities. Nor are we unsatisfied as to the
reliability of his methodology, including ascertaining the fair
market values of invested capital for comparable entities. BTR
Dunlop Holding, Inc. v. Commissioner, T.C. Memo. 1999-377.
Turning to Wilhoite’s testimony, Wilhoite, like Hahn,
considered the three principal means of valuing a company’s
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