Estate of George C. Blount, Deceased, Fred B. Aftergut, Executor - Page 16

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          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.                     

               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.                                                           

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