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income stream. Estate of Jelke v. Commissioner, T.C. Memo. 2005-
131. Value is determined under the NAV approach by computing the
aggregate value of the underlying assets as of a fixed point in
time. Id. Value is computed under the market approach by
comparison with arm’s-length transactions involving similar
companies. Id. The NAV approach is often given the greatest
weight in valuing interests in an investment company. See Estate
of Ford v. Commissioner, T.C. Memo. 1993-580, affd. 53 F.3d 924,
927-928 (8th Cir. 1995) (citing Rev. Rul. 59-60, sec. 5, 1959-1
C.B. 237, 242).
After determining the NAV of KLLP and KLBP LLC, it is
appropriate to discount decedent’s interest in each entity to
reflect lack of control and/or lack of marketability. See
Peracchio v. Commissioner, T.C. Memo. 2003-280.
2. Expert Opinions
a. In General
In deciding valuation cases, courts often look to the
opinions of expert witnesses. Each party in this case relies on
an expert opinion to determine the values of the properties at
issue. We evaluate expert opinions in light of all the evidence
in the record, and we are not bound by the opinion of any expert
witness. Helvering v. Natl. Grocery Co., 304 U.S. 282, 295
(1938); Shepherd v. Commissioner, 115 T.C. 376 (2000), affd. 283
F.3d 1258 (11th Cir. 2002). We may reject, in whole or in part,
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