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on his expert’s, Mr. Shaked’s, discounted value of $9,225,837 but
does not seek to increase the amount determined in the notice of
deficiency.
We are not constrained to follow an expert’s opinion where
it is contrary to the Court’s own judgment, and we may adopt or
reject expert testimony. Helvering v. Natl. Grocery Co., 304
U.S. at 295; Silverman v. Commissioner, 538 F.2d 927, 933 (2d
Cir. 1976) (and cases cited thereat), affg. T.C. Memo. 1974-285.
In attempting to value the interest in CCC, the estate’s
expert, Mr. Frazier, considered the three traditional valuation
approaches--income, market, and asset. Under the income
approach, value is determined by computing a company’s income
stream. Under the market approach, value is determined by
comparison with arm’s-length transactions involving similar
companies. Finally, under the asset approach, value is
determined by computing the aggregate value of the underlying
assets as of a fixed point in time.
After discussing several methods, Mr. Frazier used what he
described as a combination of the market and asset approaches.
Mr. Frazier used the market approach to value CCC’s securities.
Purporting to rely on the asset approach to valuation, Mr.
Frazier then reduced the total of the market prices for CCC’s
securities by the liabilities shown on CCC’s books and the tax
liability that would have been incurred if all of CCC’s
securities had been sold on decedent’s date of death. Mr.
Frazier did not make adjustments to the tax liability for the
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