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AS COMPETITORS CONTINUE to falter, Goldman Sachs (ticker: GS) has reaped profits from recent rallies in equities and fixed-income securities and has positioned itself to benefit from a global recovery. But a recent $55 million selling spate by two insiders may be suggesting the stock has gotten ahead of itself.

J. Michael Evans, a vice chairman at Goldman, sold 70,000 shares on Nov. 23 for $12 million, or an average price of $171.73 each. On Nov. 25, he sold 70,000 additional shares for $11.7 million, or an average price of $167.39 each.

After the sales, Evans held 644,953 shares directly and 830,967 shares through exercisable options and restricted-stock units. His stake remains less than 1% of the bank's outstanding shares.

Another vice chairman, Michael S. Sherwood, exercised options and sold 182,860 shares for about $31.9 million between Nov. 13 and Nov. 24.

Goldman shares have risen 18% over the past six months, the same as the gain for JPMorgan Chase (JPM), but far more than the 5% gain for rival Morgan Stanley (MS).

A spokesman for Goldman declined to comment on Evans' sale.

On Oct. 15, Goldman reported better-than-expected third-quarter earnings, helped by strong performances in credit products, mortgages and equities.

Goldman is a global financial-securities firm, offering investment banking, securities and investment-management services to corporations, financial institutions and wealthy individuals. The company was founded in 1869 and had $55 billion in revenue in 2008.

Evans has been with Goldman since 1993. He was appointed vice chairman in 2008 and has been chairman of Goldman Sachs Asia since 2004. Prior to that, he was co-head of the firm's securities and equities divisions.

Ben Silverman, director of research at InsiderScore.com, says the sales by Evans and Sherwood are concerning. When Sarah G. Smith, the firm's controller and principal accounting officer, sold shares in October, she was only the third insider to do so this year.

Silverman noted then that further insider sales would raise a red flag about whether Goldman is worth more now than it was at its all-time high in October 2007, as the stock's valuation suggested.

As it turned out, Silverman says, Smith's sale this year pinpointed a top in the stock. While the more recent selling has happened after the stock has backslid a bit, it still raises the question of valuation again.

"At the end of the year, there's always a lot of tax issues for insiders, so you could attribute this to that," Silverman says. "But it's very well known that Goldman employees are getting huge end-of-year bonuses. Everybody involved here should be getting a big influx of cash in the next few weeks."

But James Mitchell, an analyst with Buckingham Research Group, has a rosier view of Goldman's prospects. He rates the stock at Accumulate with a $244 price target.

Mitchell says the firm is attractively valued at 7.9 times his 2011 estimated earnings per share and 1.4 times 2010 estimated tangible book value (TBV). This compares to historical averages of 11-12 times forward EPS and well more than 2.0 times TBV.

"We also believe Goldman's strong execution and risk-management skills, and its significant leverage to a global recovery in the capital markets, make it an attractive investment," he wrote in a research note.