- 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.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011