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buy or sell. Estate of Hall v. Commissioner, 92 T.C. 312, 335
(1989). It is implicit that the buyer and seller would aim to
maximize profit and/or minimize cost in the setting of a
hypothetical sale. Estate of Watts v. Commissioner, 823 F.2d
483, 486 (11th Cir. 1987), affg. T.C. Memo. 1985-595; Estate of
Newhouse v. Commissioner, 94 T.C. 193, 218 (1990). Therefore, we
consider the view of both the hypothetical seller and buyer.
Kolom v. Commissioner, 644 F.2d 1282, 1288 (9th Cir. 1981), affg.
71 T.C. 235 (1978).
In this case, the estate reported Harlee’s value to be
$2,091,750 on its estate tax return. For purposes of this
controversy, the estate contends that the value is, at most, less
than one-half of the amount it reported. A valuation amount
reported on a taxpayer’s return is a deemed admission. Estate of
Hall v. Commissioner, supra at 337-338.
The estate argues that the Sherman Appraisal, upon which the
estate relied in filing its 1995 estate tax return, was
erroneous. Specifically, the estate contends that the appraisal
by Mr. Sherman: (1) Inferred, mistakenly, that he had interviewed
the decedent; (2) stated, alternatively in different paragraphs
on the same page, that the estate to be valued was of Mrs. Lee
Leichter or of Mr. Harvey Leichter; (3) reported that decedent’s
date of death was October 18, 1995, when it was October 23, 1995;
(4) determined that the working capital was excessive without
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