- 29 - 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 advancedPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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