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1986, and March 31, 1987. To decide the value of that stock, we
must decide the following issues:
(1) The value of Kosman, Inc.'s 12,834 shares of
Scottsbluff National Corp. stock. We hold that it was $3,278,009
on September 30, 1986, and $3,530,454 on March 31, 1987.
(2) The value of Kosman, Inc.'s 2,000 shares of Western
National Bank stock. We hold that it was $120,000 on
September 30, 1986, and $144,000 on March 31, 1987.
(3) The value per share before discounts of Kosman, Inc.,
voting and nonvoting common stock. We hold that it was $219.80
on September 30, 1986, and $247.45 on March 31, 1987.
(4) The appropriate discounts to apply in valuing the
Kosman, Inc., stock that petitioner gave to her children. We
apply a minority interest discount of 10 percent and a lack of
marketability discount of 15 percent to the voting and nonvoting
shares, and a 4-percent discount for lack of voting power to the
nonvoting shares.
The fair market value of Kosman, Inc., stock that petitioner
gave to her children after applying the discounts in (4) to the
value per share of Kosman, Inc.'s stock in (3) is as follows:
Petitioner's Respondent's
Date Stock Expert Experts Holding
9/30/86 Voting common $116.24 $294 $164.85
Nonvoting 100.74 282 156.06
common
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