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Mr. Weiksner valued the trust’s 49.04-percent interest in JPMS
common stock (1,226 shares) at $20,634,000 to $25,489,000, with a
midpoint value of $23,062,000.
Mr. McGraw’s comparative companies analysis resulted in a
$29.5 million value for the 1,226 shares of JPMS common stock. His
discounted cashflow analysis resulted in a $27.2 million value for
the 1,226 shares of JPMS common stock.
Mr. Hanan determined an $81 million fair market value for the
1,226 shares of JPMS common stock under his comparable companies
analysis. Although Mr. Hanan proposed an $81 million fair market
value for the 1,226 shares of JPMS common stock, he conceded that
because of a likely disagreement between the buyer/seller and Mr.
DeJoria over Mr. DeJoria’s compensation and the possibility of
litigation, the value of the subject stock could be as high as
$165.3 million and as low as $57.7 million.
Expert witness reports may help the Court understand an area
requiring specialized training, knowledge, or judgment. Snyder v.
Commissioner, 93 T.C. at 534. We may be selective in deciding what
part of an expert witness’s report we will accept. Helvering v.
Natl. Grocery Co., 304 U.S. 282, 295 (1938); Parker v.
Commissioner, 86 T.C. 547, 561 (1986). The purpose of expert
testimony is to assist the trier of fact to understand evidence
that will determine the fact in issue. Laureys v. Commissioner, 92
T.C. 101, 127-129 (1989). An expert has a duty to the Court that
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