- 10 - Notices of Deficiency Respondent issued separate notices of deficiency to petitioners.4 Petitioners thereafter timely filed petitions with this Court objecting to the notices of deficiency. Respondent agreed with E&Y’s freely traded values of Huber shares; however, respondent took issue with the appropriate discount for lack of marketability because of a report by respondent’s expert, Appraisal Economics, Inc. While E&Y has always applied a 50-percent discount since its employment with Huber in 1993, respondent’s expert applied a 30-percent discount for 1997, a 25-percent discount for 1998, a 45-percent discount for 1999, and a 30-percent discount for 2000. The discrepancies in valuation of the shares are as follows: Year Petitioners’ Value Respondent’s Value 1997 $45.75 $64.05 1998 51.50 77.25 1999 47.50 52.25 2000 58.00 81.20 Respondent also rejected the E&Y values because he determined the sales at these values were not arm’s-length transactions. The threshold issue at trial was whether there 4Respondent issued separate notices of deficiency determining deficiencies in the gift tax of petitioners Michael A. and Caroline P. Huber for the tax years 1997, 1998, 1999, and 2000; Tabitha A. Huber for the tax years 1997 and 1998; and Hans A. and Laurel D. Huber for the tax year 1997.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011