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938, 940 (1982) (for unlisted stocks, near contemporaneous sales,
in the normal course of business, are the “best criteria of
market value”). Poesch, however, owned only 15 percent of the
common stock of the company. No doubt, therefore, he was forced
to accept some discount. Estate of Jung v. Commissioner, 101
T.C. 412, 434 (1993) (“Cases involving the valuation of minority
holdings in close corporations ordinarily consider a discount or
discounts because the stock is a minority holding and is not
publicly traded.”). Poesch did not testify, since he died
shortly after decedent. We cannot determine from the evidence in
the record how much discount Poesch was forced to bear. In other
words, we cannot work backwards from the $290 a share accepted by
Poesch to an undiscounted value. We are unpersuaded that the
undiscounted value of Poesch’s shares was $440 (the amount
determined for the common shares under the 1987 redemption
agreement). Although we have considered Poesch’s sale in
determining the value of decedent’s shares as of the alternate
valuation date, see infra section V, we do not believe that that
sale is persuasive evidence that the price to be paid for the
decedent’s stock under the 1987 redemption agreement reflected
adequate and full consideration in money or money’s worth when
the agreement was executed. For the reasons stated, and
considering the record as a whole, we find that the executors
have failed to carry their burden of proving that the price to be
paid for decedent’s shares under the 1987 redemption agreement
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