-26-
after the valuation date. Estate of Andrews v. Commissioner, 79
T.C. 938, 940 (1982); Estate of Noble v. Commissioner, T.C. Memo.
2005-2. When arm’s-length sales of unlisted stock are
unavailable or inconclusive, the value of closely held stock
shall be determined by considering all other available financial
data and all relevant factors that would affect fair market
value. Rev. Rul. 59-60, 1959-1 C.B. 237. These factors include
the corporation’s net worth, prospective earning power, dividend-
paying capacity, and other factors. Estate of Andrews v.
Commissioner, supra at 940; sec. 20.2031-2(f), Estate Tax Regs.;
Rev. Rul. 59-60, sec. 4.01, 1959-1 C.B. at 238. These factors
cannot be applied with mathematical precision, and the weight
given to each factor must be considered in light of the
particular facts of each case. Estate of Andrews v.
Commissioner, supra at 940-941.
B. Expert Opinions
Both parties submitted expert reports providing valuations
of the estate’s Kohler stock as of the alternate valuation date,
which considered many different factors and ascribed different
weights for each, resulting in a wide range of proposed
valuations.8 See Estate of Deputy v. Commissioner, supra. The
8Both parties also submitted expert reports providing
valuations of the stock as of Frederic’s date of death. The
expert report the estate submitted as of Frederic’s date of death
concluded that the value of the stock was higher on the date of
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