- 21 - the sales was of a 49-percent interest. Of the 42 remaining sales, 4 were for a gross income multiplier (multiplier) of less than 2.5, 18 were at a multiplier of above 3, and 19 were in the range of 2.5 to 3. Of the 4 sales that were at a multiplier of less than 2.5, one was at 2.2, one at 2.36, and two at 2.41. The sale at a multiplier of 2.2 involved only 2 billboard faces. The sale at a multiplier of 2.36 was primarily of poster billboards. The highest of the 42 sales was at a multiplier of 4.1. The prime interest rate, the rate a bank charges to its best customers, was between 15.75 and 16.5 percent from prior to December 1981 to February 1982. Listed below are the yields as of January 1982 on the following types of securities: Type of security Rate of return Corporate bonds (Aaa) 15.8% Corporate bonds (A) 16.19 U.S. bonds--5 years 15.5 U.S. bonds--10 years 14.57 A notice of deficiency was timely mailed to petitioner in docket No. 22456-91 on July 17, 1991, with respect to the estate tax liability. A notice of deficiency was timely mailed to petitioner in docket No. 564-93 on October 27, 1992, with respect to the gift tax liability of decedent for the year ended December 31, 1982. Respondent in her notice of deficiency in gift tax stated with respect to the value of gifts made by decedent in 1982 as follows:Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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