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Western National Bank paid no dividends in 1985 and
dividends of 80 cents per share in 1986.
12. Petitioner's Gifts of Shares in Kosman, Inc.
Before September 30, 1986, petitioner owned 2,340 shares
(46.8 percent) of the voting common stock of Kosman, Inc.; 2,340
shares (46.8 percent) of the nonvoting common stock of Kosman,
Inc.; and 5,616 shares (46.8 percent) of the voting preferred
stock of Kosman, Inc. On September 30, 1986, and March 31, 1987,
petitioner gave the following shares of Kosman, Inc., stock to
her children:
Date Of Voting Nonvoting
Donee Gift Common Shares Common Shares
H.H. Kosman 9/30/86 1,703.41 --
Dianna Kosman 9/30/86 -- 1,281.54
Ann Burkholder 9/30/86 223.08 1,058.46
3/31/87 348.41 --
Those gifts are the subject of this case. Petitioner also
gave 94.77 and 530 shares of Kosman, Inc., voting preferred stock
to Ann Burkholder and Diana Kosman, respectively, on March 31,
1987. The value of that stock is not in dispute. From July 21,
1986, to the end of 1987, petitioner did not own a majority of
the outstanding voting shares of Kosman, Inc.
Petitioner and the other shareholders of Kosman, Inc., owned
the following shares of Kosman, Inc., stock on the dates shown:
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