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appraisals, neither of which is in the record and neither of
which included a marketability discount. Respondent determined
that the Decedent’s CGT stock was worth $15,440,000 on the
alternate valuation date. The parties have since stipulated that
the June 11, 1990, value of the Decedent’s CGT stock was
$12,250,000, without regard to any marketability discount or
control premium that may otherwise apply. The parties’
stipulation followed their receipt of appraisals of the stock’s
value as of June 11, 1990. Respondent’s sole appraisal stated
that the stock was worth $12,619,000. Petitioner’s three
appraisals stated that the stock was worth $11,625,000,
$11,652,555 and $11,850,000, respectively.
In making these appraisals, all of the appraisers relied
primarily upon transactional and financial data compiled by
Paul Kagan Associates, Inc. (Kagan), and none of the appraisers
determined CGT’s value by reference to the price of stock that
was listed on a public exchange. The transactions reported by
Kagan included recent transactions in which stock of television
stations was transferred at arm's length. All of the appraisers
also considered the nature of CGT, its history, its position in
the industry, its economic outlook, and other factors listed in
Rev. Rul. 59-60, 1959-1 C.B. 237 (regarding the valuation of
stock for Federal estate tax purposes).
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