Jane O. Kosman - Page 17

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                  In preparing her 1986 and 1987 returns, petitioner retained                             
            the certified public accounting firm of Grant Thornton to                                     
            appraise the shares.  Petitioner reported the values that Grant                               
            Thornton placed on them.                                                                      
                  In the notice of deficiency, respondent determined that the                             
            fair market value of voting and nonvoting Kosman, Inc., stock was                             
            $223.60 per share on September 30, 1986, and $240.68 per share on                             
            March 31, 1987.  In an amended answer, respondent alleged that                                
            the fair market value per share of the voting and nonvoting                                   
            common stock of Kosman, Inc., on September 30, 1986, and                                      
            March 31, 1987, was $294 for voting shares and $282 for nonvoting                             
            shares.                                                                                       
                  Respondent's position in the amended answer results in a                                
            larger gift tax deficiency than respondent determined in the                                  
            notice of deficiency.                                                                         
            14. Purchases of Scottsbluff National Corp. Stock From Former                                 
                  Employees and Others                                                                    
                  There were a few sales of shares of Scottsbluff National                                
            Corp. stock from 1984 to 1988 involving directors and longtime                                
            employees.  These were sales of minority interests.                                           
                  Several stock purchase agreements were made with directors                              
            and employees of Scottsbluff National Bank before 1986.  One of                               
            the agreements, made many years before 1986, set a sales price                                
            for Scottsbluff National Bank stock equal to 90 percent of the                                
            shares' book value.  Two other agreements set a sales price equal                             




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