Jane O. Kosman - Page 3

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            3/31/87   Voting common     131.76          294        185.58                                 
            Nonvoting         114.19          282        175.69                                           
            common                                                                                        
                  Section references are to the Internal Revenue Code in                                  
            effect for the years in issue.  Rule references are to the Tax                                
            Court Rules of Practice and Procedure.                                                        
                                           FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are so found.                                
            1.    Petitioner                                                                              
                  Petitioner lived in Scottsbluff, Nebraska, when she filed                               
            the petition in this case.                                                                    
                  In 1986 and 1987, the stock of Scottsbluff National Corp.                               
            was held by members of the Kosman, Lindig, and Ostenberg-                                     
            Fleisbach families, and by current and former employees and                                   
            directors of Scottsbluff National Bank.  Harve Ostenberg formerly                             
            was the majority shareholder and president of Scottsbluff                                     
            National Bank.  Harve Ostenberg and his first wife are                                        
            petitioner’s parents.  The Lindig family members inherited their                              
            stock in Scottsbluff National Corp. from William Ostenberg.                                   
            William Ostenberg was Harve Ostenberg's brother and a shareholder                             
            of Scottsbluff National Bank.  The members of the Ostenberg-                                  
            Fleisbach family derived their stock in Scottsbluff National Bank                             
            from C.S. Ostenberg and C.H. Fleisbach.  C.S. Ostenberg and C.H.                              
            Fleisbach were sons of Harve Ostenberg's second wife and her                                  
            first husband.                                                                                




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