- 16 - that decedent’s BCC stock had a fair market value of $7,921,975. The estate timely petitioned this Court for redetermination. VII. Expert Testimony The estate submitted the expert report and testimony of John T. Grizzle in support of its contention that the terms of the buy-sell agreement at issue were comparable to similar agreements entered into by persons in arm’s-length transactions within the meaning of section 2703(b)(3). In light of the possibility that the value stipulated in the buy-sell agreement at issue would be disregarded in this proceeding, both the estate and respondent submitted expert reports and testimony regarding the fair market value of decedent’s BCC stock as of the valuation date. The estate offered Mr. Grizzle and Gerald M. Fodor as experts in valuation of closely held companies. Respondent offered James R. Hitchner.10 10 Before trial, respondent also indicated that he would seek to have the appraisals of BCC performed by BVS for purposes of the ESOP received into evidence as party admissions. Respondent has not maintained this contention on brief, and we deem it abandoned. See Bradley v. Commissioner, 100 T.C. 367, 370 (1993); Sundstrand Corp. v. Commissioner, 96 T.C. 226, 344 (1991); Rybak v. Commissioner, 91 T.C. 524, 566 n.19 (1988). Moreover, neither party made any attempt to comply with the requirements of Rule 143(f) for submitting the BVS appraisals as expert testimony.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011