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well as the voting rights (as trustee) with respect to all of
Joseph's stock. The parties do, however, dispute the value of
the interests that Cyril received. In her notice of deficiency,
respondent permitted an offset for the value of consideration
received by Cyril in the amount of $43,878. However, as
previously mentioned, respondent amended her answer to disallow
any such offset. On brief, respondent argues that in the event
that this Court finds that there was consideration, the amount of
the offset pursuant to section 2043(a) is limited to $30,752,
based on the report and testimony of her expert appraiser,
Stephen A. Stewart. Petitioner contends that the value of what
Cyril received on October 31, 1951, is $58,146, based on the
report and testimony of its expert appraiser, Bryan H.
Browning.13
Both experts determined the overall value of JM and
Specialty using a combination of a discounted future cash-flow
analysis and a market comparable analysis. The experts differ in
their application of premiums or discounts in arriving at the
value of the consideration received by Cyril. Mr. Browning,
petitioner's expert, applied a control premium of 40 percent to
the proportional equity value of JM, because after execution of
the 1951 Agreement, Cyril would hold 62 percent of the total
13The difference between the values assigned by each party
to the consideration received, $27,394, is not significant when
one considers the value of the trusts includable in the gross
estate, which is equal to $3,833,727.
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