- 13 - Respondent’s Expert Respondent’s expert, Smith, valued decedent’s C&L Bailey stock on the basis of the adjusted book value of the corporation’s net assets.2 In doing so, he adopted without change the appraised values of the California motel and the Arkansas motel as reflected in the Ohrmund report and the original Biles report, respectively. Like the Ohrmund report, Smith’s report makes no adjustment in the California motel value for decedent’s individual one-half ownership interest in parcel 2. In determining a $415,319 value for decedent’s 50 shares of C&L Bailey stock, Smith allowed a 20-percent minority-interest discount and a 27.44-percent discount for lack of marketability. Petitioner’s Experts Petitioner offered two expert witnesses: (1) Richard L. Schwartz (Schwartz), who is a certified public accountant and certified business appraiser; and (2) Biles, who, as previously discussed, is the Arkansas appraiser who prepared the original Biles report valuing the Arkansas motel. Like Smith, Schwartz valued decedent’s C&L Bailey stock by reference to the adjusted book value of the corporation’s net assets. Like Smith, Schwartz adopted the appraised value of the 2 As previously discussed, Dennis C. Smith (Smith) also prepared the October 1996 valuation report from which respondent derived the C&L Bailey stock values reflected in the notice of deficiency.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011