Peter S. Peracchio - Page 11

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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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