Estate of Joseph R. Cloutier, Joseph A. Cloutier, Fiduciary - Page 4

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          appraisals, neither of which is in the record and neither of                
          which included a marketability discount.  Respondent determined             
          that the Decedent’s CGT stock was worth $15,440,000 on the                  
          alternate valuation date.  The parties have since stipulated that           
          the June 11, 1990, value of the Decedent’s CGT stock was                    
          $12,250,000, without regard to any marketability discount or                
          control premium that may otherwise apply.  The parties’                     
          stipulation followed their receipt of appraisals of the stock’s             
          value as of June 11, 1990.  Respondent’s sole appraisal stated              
          that the stock was worth $12,619,000.  Petitioner’s three                   
          appraisals stated that the stock was worth $11,625,000,                     
          $11,652,555 and $11,850,000, respectively.                                  
               In making these appraisals, all of the appraisers relied               
          primarily upon transactional and financial data compiled by                 
          Paul Kagan Associates, Inc. (Kagan), and none of the appraisers             
          determined CGT’s value by reference to the price of stock that              
          was listed on a public exchange.  The transactions reported by              
          Kagan included recent transactions in which stock of television             
          stations was transferred at arm's length.  All of the appraisers            
          also considered the nature of CGT, its history, its position in             
          the industry, its economic outlook, and other factors listed in             
          Rev. Rul. 59-60, 1959-1 C.B. 237 (regarding the valuation of                
          stock for Federal estate tax purposes).                                     








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