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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:
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