-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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011