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“Valuing a Business.” Robert Schweihs (Mr. Schweihs) was the WMA
appraiser who handled the valuation of the estate’s stock, and
Natalie knew he was well recognized in the field and was co-
author of “Valuing a Business.” Natalie gave Mr. Schweihs all
the information he requested in connection with his appraisal.
WMA’s appraisal report determined that the fair market value
of the Kohler stock held by the estate as of September 4, 1998,
was $47.010 million.5 WMA also determined that the value of the
Kohler stock held by the estate on the date Frederic died was
$50.115 million. Natalie attached the appraisal reports to the
estate tax return the estate filed. Natalie elected to value all
of the property in Frederic’s gross estate as of the alternate
valuation date of September 4, 1998, and reported the value of
the Kohler stock on that date, $47,009,625, on the estate tax
return.
During examination of the estate’s return, respondent
requested numerous documents, many of which the estate produced.
Respondent issued a summons to the estate to obtain certain
documents dealing with post-valuation date events and documents
containing sensitive Kohler business information. The estate
filed a motion to quash the summons. Natalie, as personal
representative of the estate, was concerned about the relevancy
5See supra note 3 for a discussion of a minor inconsistency
between the estate tax return, the parties’ stipulations, and the
WMA appraisal.
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