Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator - Page 34

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          time.  For this reason, we conclude that the lower end of Mr.               
          Ruppert's scale of 2.5 to 3 is an appropriate multiplier to be              
          applied to the net sales of SOAI for 1981 to obtain the fair                
          market value of the assets of SOAI on January 25, 1982.  We,                
          therefore, hold that an asset sale of SOAI on January 25, 1982,             
          should be at a multiplier of 2.5 applied to SOAI's net sales for            
          the year 1981.  The fair market value of the SOAI stock can be              
          ascertained from this figure by making the adjustments made by              
          respondent's witness, Mr. Loe.                                              
               The parties stipulated that the value of the SOAI stock                
          transferred by decedent in 1980 and 1981 is the same as the value           
          as of January 25, 1982, subject to any discount that the Court              
          might determine applicable for marketability or minority interest           
          due to the smaller number of shares transferred.  There is not              
          very much in the record with respect to an appropriate amount of            
          either a marketability discount or minority interest discount.              
          Respondent, to some extent, seems to contend that the 1980 and              
          1981 transfers were part of the same overall plan as the 1982               
          transfer.  However, these transfers appear more to be a                     
          continuation of small gifts made by decedent to his family in               
          prior years than part of the plan to give his son John the                  
          majority interest in SOAI in 1982.  There is very little evidence           
          in the record as to an appropriate amount for a marketability               
          discount or a minority interest discount.  Obviously, if all of             
          the assets were sold, the minority shares would have the same per           




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