Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator - Page 21

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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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