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asset for petitioner in satisfaction of the debt. Petitioner
testified that although both items appeared on ZSI’s 1992
financial records, neither item should have so appeared.
Petitioner’s testimony is not supported by the record.
Petitioner did not introduce any evidence, other than his own
testimony, to show that he was the stockholder to whom ZSI’s debt
was payable or that ZSI purchased the nonoperating asset in
satisfaction of the debt. We do not accept petitioner’s
completely uncorroborated testimony as persuasive proof that
respondent improperly included the nonoperating asset in
calculating ZSI’s value, in the face of the evidence that the
asset was listed on ZSI’s balance sheet at a value approximating
$170,000. Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
Conclusion
Petitioner disputed a number of respondent’s assumptions in
valuing ZSI for purposes of Federal gift tax, but we are
persuaded that respondent’s valuation is supported by the
evidence. We therefore conclude that ZSI’s value on the
valuation date was 88 cents per share, as respondent’s expert
calculated.
We have considered all of petitioner’s arguments for a
different result, and, to the extent not discussed herein, we
find them moot, irrelevant, or without merit.
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