- 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 equal
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: May 25, 2011