Estate of Joseph R. Cloutier, Joseph A. Cloutier, Fiduciary - Page 12

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               Because the record does not show that a marketability                  
          discount applies to the stipulated value of the Decedent’s CGT              
          shares, we hold that no discount for marketability is allowable.7           
          In so holding, we have considered all arguments made by                     
          petitioner, and, to the extent not discussed above, have found              
          them to be without merit.                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
          under Rule 155.                                                             





















          7 Respondent argues that the fact that the Decedent                         
          controlled CGT means that a control premium exists to the extent            
          of any marketability discount.  Based on our holding, we need               
          not, and do not, address this argument.                                     






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