Leo J. Polack - Page 18




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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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