-41-
like Kohler. We accordingly give significant weight to their
valuations.
IV. Valuation of the Estate’s Stock
As previously stated, we give no weight to respondent’s
expert’s valuation of the estate’s stock. Respondent failed to
introduce any evidence or present any arguments to persuade us
that the value reported on the estate’s tax return was incorrect,
and accordingly respondent has failed to meet his burden of
proof. In contrast, both of the estate’s experts provided
thoughtful valuations reflecting the true nature of the Kohler
business and used valuation methods considered reliable for
privately held companies like Kohler. Each valuation provided
persuasive support for the value the estate reported on its
return. We ascribe great weight to both of these valuations and
further find that the estate’s experts’ reports created a range
significantly closer to the actual fair market value than
respondent’s expert found.
Accordingly, based on our review of all of the valuation
evidence, giving due regard to our observation at trial of the
witnesses for both parties and considering their testimony and
the expert reports, we conclude that the fair market value of the
Kohler stock owned by the estate on the alternate valuation date
was $47,009,625.
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