- 17 - 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 equalPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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