Estate of George C. Blount, Deceased, Fred B. Aftergut, Executor - Page 56

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          294-295 (1938); Anderson v. Commissioner, 250 F.2d 242, 249 (5th            
          Cir. 1957), affg. in part and remanding in part on other grounds            
          T.C. Memo. 1956-178; Estate of Newhouse v. Commissioner, 94 T.C.            
          193, 217 (1990); Skripak v. Commissioner, 84 T.C. 285, 320                  
               Fair market value is defined for Federal estate tax purposes           
          as the price at which property would change hands between a                 
          willing buyer and a willing seller, neither being under any                 
          compulsion to buy or to sell and both having reasonable knowledge           
          of all the relevant facts.  United States v. Cartwright, 411 U.S.           
          546, 551 (1973); sec. 20.2031-1(b), Estate Tax Regs.; see also              
          Snyder v. Commissioner, 93 T.C. 529, 539 (1989); Estate of Hall             
          v. Commissioner, 92 T.C. 312, 335 (1989).                                   
               B.   Expert Testimony                                                  
               Both parties submitted expert reports and testimony in                 
          support of their asserted fair market values for decedent’s BCC             
          stock on the valuation date.30  When considering expert testimony           
          regarding valuation, we weigh the testimony in light of the                 

               30 The estate proffered Mr. Grizzle as an expert both with             
          respect to the issue of compliance with sec. 2703(b)(3) and with            
          respect to the fair market value of decedent’s shares.  For the             
          reasons outlined supra in Pt.I.C.2., we conclude that Mr.                   
          Grizzle’s expert opinion concerning the value of decedent’s                 
          shares is unreliable and assign it no weight.  Our discussion               
          hereinafter considers only the fair market value opinions of                
          Messrs. Fodor and Hitchner.                                                 

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