- 56 -
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
(1985).
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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