Herbert V. Kohler, Jr., et al. - Page 13

                                        -13-                                          
          “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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