Estate of Helen M. Noble, Deceased, Leslie H. Noble, Jr., and John R. Noble, Co-Personal Representatives - Page 4

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          Johnson issued the appraisal to Dean solely to assist the                   
          management of Glenwood Bank in making a cash purchase of the                
          shares.  The appraisal was prepared on behalf of Seim Johnson by            
          Dennis R. Hein (Hein) and concluded that the fair market value of           
          the 116 Glenwood Bank shares held by the estate was $878,004                
          ($7,569 per share) as of December 31, 1996.  The appraisal stated           
          that this fair market value included a 29-percent discount for              
          minority interest and a 35-percent discount for lack of                     
          marketability.  The estate declined to sell its Glenwood Bank               
          shares to Dean at this appraised price.  The estate sold those              
          shares to Bancorporation on October 24, 1997, for $1.1 million              
          ($9,483 per share).                                                         
               On July 18, 2001, respondent issued to the estate a notice             
          of deficiency in which he determined, among other things, that              
          the fair market value of decedent’s 116 Glenwood Bank shares was            
          $1.1 million.  The notice states that “The value of the                     
          decedent’s stock was adjusted to the fair market value as                   
          determined by Shenehon Company.”                                            
               At trial, respondent called William C. Herber (Herber) as an           
          expert witness, and the Court over the objection of petitioners             
          recognized him as an expert on the valuation of financial                   
          institutions.  The Court also over the objection of petitioners             
          accepted into evidence Herber’s expert report under Rule 143(f)             
          (Shenehon report), written on behalf of his employer, Shenehon              






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