- 24 -                                         
               Our conclusion that Dr. Spiro improperly applied the                   
          guideline company approach based upon Mondavi and Canandaigua               
          makes it unnecessary to address petitioner’s other criticisms of            
          Dr. Spiro’s application of that approach:  The selection of                 
          inappropriate financial ratios, the arbitrary adjustment of those           
          ratios, and the arbitrary nature of the weight given to the                 
          result reached by Dr. Spiro under the market approach.                      
               D.  Conclusion                                                         
               Dr. Spiro improperly applied the guideline company approach            
          in valuing the stock of Korbel.                                             
          V.  Utilization of the Discounted Cashflow Method in Valuing the            
          Stock of Korbel                                                             
               A.  Introduction                                                       
               This Court considers the discounted cashflow (DCF) method              
          employed by both experts to be an appropriate method for use in             
          valuing corporate stock.  See, e.g., N. Trust Co. v.                        
          Commissioner, 87 T.C. 349, 379 (1986).  Moreover, where we have             
          rejected use of the market approach as unreliable, we have based            
          the value of a closely held corporation on the DCF approach                 
          alone.  See Estate of Jung v. Commissioner, 101 T.C. 412, 433               
          (1993).  We, therefore, find that the DCF method utilized by both           
          experts in this case is an appropriate method for valuing the               
          stock of Korbel as of the valuation date.                                   
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