- 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.Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
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