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approximation, the figure at which we arrive need not be directly
traceable to specific testimony if it is within the range of
values that may be properly derived from consideration of all the
evidence. Estate of True v. Commissioner, T.C. Memo. 2001-167
(citing Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir.
1976), affg. T.C. Memo. 1974-285).
B. Differences Between the Experts
The major difference between Drs. Bajaj and Spiro is their
disagreement as to the propriety of utilizing a market approach
(i.e., the guideline company method) in valuing the shares.
Also, although both experts utilized a discounted cashflow
approach in valuing the shares (Dr. Bajaj, exclusively;
Dr. Spiro, in part), they disagree sharply over methodology in
applying that approach. We shall analyze the arguments presented
by both experts in support of their respective positions.
IV. Propriety of Dr. Spiro’s Application of the Guideline
Company Method
A. Introduction
The guideline company method of appraisal is commonly used
in valuing shares of stock in a closely held corporation. When
appropriate, its usage is mandated by section 2031(b), which
provides that the value of unlisted shares of stock or securities
“shall be determined by taking into consideration, in addition to
all other factors, the value of stock or securities of
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