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               Johnson concluded that CSB was worth $5,200,000 on June 30,            
          1988; 71.43 percent of that amount is $3,714,000.  Johnson said             
          that use of a control premium of 15 percent to value decedent’s             
          CSB stock would be appropriate, but he said that he took a more             
          conservative approach and did not apply a control premium.                  
          Johnson said that by not applying a premium he might be                     
          understating the value of decedent’s stock.  Johnson estimated              
          that, if he used a 15-percent control premium to value decedent’s           
          stock, the value would be $4,217,000.  Petitioner contends that             
          a 25-percent control premium should have been used, which would             
          increase the value of decedent’s stock to $4,642,500.                       
               Contrary to Johnson’s conclusion, we do not think a                    
          hypothetical willing buyer would pay anything close to $5 million           
          for decedent’s CSB stock.  CSB did not pay dividends.  Decedent             
          could not sell his CSB stock without the other shareholders’                
          consent.  Ownership of CSB stock did not entitle the shareholder            
          to any CSB earnings or profits.  There was no relationship                  
          between stock ownership in CSB and compensation.  Also, the                 
          nature of CSB’s personal injury contingency fee practice was                
          uncertain.                                                                  
               Prior sales of CSB stock by Fowler and Sucherman suggest               
          that decedent’s stock was worth less than $1,105,762 (about $110            
          per share).  CSB agreed to pay $25 per share to Fowler and $46              
          per share to Sucherman (after offsetting for the costs advanced             
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