Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator - Page 26

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          stock of SOAI to be the interest to be valued.  Neither party               
          questions the fact that a 52-percent interest, which the 424                
          shares represented, is a controlling interest under Ohio law.               
               Both parties recognize that where a gift of property is                
          made, the gift tax is based on the fair market value of the                 
          property given, which is the price at which the property would              
          change hands between a willing buyer and a willing seller, both             
          having reasonable knowledge of relevant facts.  United States v.            
          Cartwright, 411 U.S. 546, 551 (1973).                                       
               Where, as here, the property given is stock in a closely               
          held corporation which is not listed on any exchange and of which           
          there have been no sales, it is difficult to determine fair                 
          market value.  Very often fair market value can be determined by            
          reference to sales of stock of publicly held comparable                     
          corporations.  However, no witness in this case, including each             
          of petitioner's expert witnesses and each of respondent's expert            
          witnesses, knew of any sale of stock of any outdoor advertising             
          company.   The experts offered by each party stated that                    
          generally where there was a sale of an outdoor advertising                  
          company, the sale would be of the assets, since the value of the            
          company was primarily in its leases and billboards on those                 
          leases.  The experts offered by each of the parties stated that             
          there might have been some sale of stock of an outdoor                      
          advertising company, but they knew of none.  However, they were             
          aware of a number of sales of the assets of outdoor advertising             




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