Estate of Josephine T. Thompson, Deceased, Carl T. Holst-Knudsen and the Bank of New York, Executors - Page 54

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          to the appropriateness of the section 6662 penalty that even                
          respondent’s expert made significant errors in his various                  
          calculations.                                                               
               Complicating the valuation presented to the parties and to             
          the Court herein was the difficult question as to how the                   
          Internet and the risks and opportunities associated therewith               
          should be regarded as affecting TPC.  The evaluation in this case           
          of such intangible risks and opportunities was difficult and                
          imprecise.                                                                  
               Certainly, the experts for the estate were aggressive in               
          their relatively low valuation of TPC.  Respondent’s expert was             
          aggressive in his relatively high valuation of TPC.  We note that           
          our valuation of TPC and of the estate’s 20-percent interest in             
          TPC is closer to the estate’s valuation than to respondent’s                
          valuation.                                                                  
               On the record before us, we believe it inappropriate to                
          impose the accuracy-related penalty.  The estate is not liable              
          for the accuracy-related penalty.                                           
               Accordingly,                                                           

                                             Decision will be entered                 
                                        under Rule 155.                               










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