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values that may be properly derived from consideration of all the
evidence. Estate of True v. Commissioner, T.C. Memo. 2001-167
(citing Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir.
1976), affg. T.C. Memo. 1974-285).
B. Petitioner’s Experts
Petitioner offered Timothy R. Dankoff and Charles H. Stryker
as expert witnesses to testify concerning the value of the
transferred interests. Mr. Dankoff is a partner in Plante &
Moran, LLP, an accounting and management consulting firm. He is
accredited as a senior appraiser by the American Society of
Appraisers and has been involved in business valuation activities
since 1986. Mr. Stryker is a partner in the valuation and
appraisal group of BDO Seidman, LLP, an accounting and consulting
firm. He has been performing valuation services for
approximately 25 years. The Court accepted Mr. Dankoff and Mr.
Stryker as experts in valuation and received into evidence as
their expert testimony their respective written analyses
regarding the value of the transferred interests.
In his written report, Mr. Dankoff concludes that, based on
a 7.7-percent minority interest discount and a 35-percent
marketability discount, the fair market values of the gifted
interest and the sold interest on November 30, 1997 (5 days after
the valuation date), were $550,000 and $646,764, respectively.
Mr. Stryker concludes in his written report that, based on a 5-
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