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by CSB on cases Sucherman took with him from CSB). Johnson
concluded that decedent’s stock was worth more than $500 per
share, more than 10 times the value of Sucherman’s stock a year
earlier. The record does not support a finding that decedent’s
stock was worth 10 times as much per share as Sucherman’s stock.
Petitioner argues that we should use a 25-percent control
premium to value decedent’s CSB stock, citing Estate of Salsbury
v. Commissioner, T.C. Memo. 1975-333 (38.1-percent control
premium applied in valuing a decedent’s 51.8-percent stock
interest in corporation where the decedent controlled the
corporation, including the ability to elect himself president of
the corporation, to declare dividends, and to set his own
compensation). Johnson said a 15-percent control premium would
not be improper, although he did not apply one. Spiro testified
that a 15-percent control premium was appropriate. We accept the
conclusion of the experts that a 15-percent control premium is
appropriate here. Adjusting for a control premium, we find that
the value of decedent’s stock was $1,105,762.
3. Conclusion
The record amply supports finding a value for decedent’s CSB
stock equal to or less than that determined by respondent. Thus,
using Spiro’s appraisal method, we value decedent’s CSB stock as
follows:
Decedent’s initial stock investment $10,000
Amount of earned but unpaid profits
as of June 30, 1988 1,256,631
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