Tax Court Determines That Value Was 'Somewhere in the Middle' of Expert Opinions

Business Valuation UpdateVol. 9 No. 10
Legal and Court Case Update
October 2003
3559 Special Industry Machinery, NEC
332410 Power Boiler and Heat Exchanger Manufacturing
estate and gift taxation
net asset value, asset approach, discount for lack of marketability (DLOM), discounted cash flow (DCF), fair market value (FMV), gift tax, shareholder agreement, noncompete agreement, discount for lack of control (DLOC), guideline publicly-traded company method

Hess v. Commissioner
T.C. Memo 2003-251
August 20, 2003
Federal Court
United States Tax Court
Gregory Heebink, CFA (for taxpayer) <br> Eric Engstrom, CPA/ABV, CFA (for IRS)


The taxpayers' expert, Gregory Heebink, used the discounted cash flow (DCF) method and the guideline public company method.

See Also

Hess v. Commissioner

Taxpayers gave 10 shares of HII common stock (a 10% stockholder interest) to an irrevocable trust established for their daughter. Issue was the fair market value of the stock for gift tax p ...