At issue in this proceeding is the valuation of certain gifts of stock made by petitioner and decedent in 1976. Inasmuch as the stock was not publicly traded, valuation of these gifts was difficult, and an independent appraiser was hired to appraise the stock for gift tax purposes. The appraiser valued the stock at net asset value discounted 57.8% due in part to the fact that the stock was not publicly traded. Upon auditing petitioner's and...
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