While consolidating various medical service corporations into a single medical practice group, taxpayers donated stock to a charity and claimed charitable contribution deductions of $401 per share. Because taxpayers’ valuation experts erroneously treated the corporation as a going concern, the Tax Court declined to rely on their reports in determining the FMV of the donated stock. Agreeing with the IRS’s expert that the asset-based approach was a more accurate valuation method, the Tax Court valued the stock at $37 per share and imposed accuracy-related penalties on the taxpayers. Bradley Bergquist , 131 TC No. 2 (Tax Ct.).