- 23 -                                         
               Another factor which makes Mr. Heebink’s analysis less                 
          persuasive is his application of a minority interest discount to            
          the total business enterprise value he determined in his                    
          analysis.  A significant component of this total business                   
          enterprise value is attributable to his market comparable                   
          analysis.  Applying a minority interest discount to the market              
          comparable analysis, which already reflects transactions                    
          involving minority interests, is inappropriate.  See Estate of              
          Mitchell v. Commissioner, T.C. Memo. 2002-98 (if the stock to be            
          valued by the market approach represents a minority interest, no            
          discount for the lack of control is applied because the method              
          reflects a minority interest).                                              
               We do not agree with respondent that Mr. Heebink’s                     
          discounted cashflow analysis is entitled to no consideration.  We           
          will consider Mr. Heebink’s valuation analysis, bearing in mind             
          the circumstances identified above, especially the fact that his            
          analysis significantly understated the value of HII stock in                
          making the erroneous adjustment for the alleged understatement of           
          reserves.23                                                                 
               22(...continued)                                                       
          in valuing HII stock.  However, we agree that it detracts from              
          the persuasiveness of Mr. Heebink’s conclusions.                            
               23Mr. Heebink does not present an alternative valuation                
          which does not contain this adjustment; however, it is clear that           
          this adjustment, if corrected, would bring Mr. Heebink’s                    
          conclusions considerably closer to those of Mr. Engstrom’s.                 
                                                             (continued...)           
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