Michael W. and Caroline P. Huber et al. - Page 10

                                       - 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.                               





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