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to the shares' unadjusted book value. Several of these stock
purchase agreements set a sales price equal to 1.15 times the
shares' unadjusted book value.
In 1984, petitioner bought 500 shares of Scottsbluff
National Corp. stock from the estate of Ruth Witters for a price
equal to 1.15 times the shares' book value. Ruth Witters was the
widow of a former longtime employee and vice president of
Scottsbluff National Bank.
On April 11, 1988, Kosman, Inc., bought 100 shares of
Scottsbluff National Corp. stock from Robert Berggen for $430.85
per share. The price approximately equaled the book value per
share. Robert Berggen had been a director of Scottsbluff
National Corp. He agreed to sell the shares when he left the
board of the corporation.
On November 23, 1988, the Estate of Lawrence Baltas sold a
total of 100 shares of Scottsbluff National Corp. stock to 10
different parties, including Kosman, Inc., for $543 per share.
On that date, Kosman, Inc., bought 10 shares from the estate for
$543 per share. The price exceeded the book value per share.
Lawrence Baltas had been a shareholder of Western National Bank.
He acquired his Scottsbluff National Corp. shares when Western
National Bank and Scottsbluff National Bank merged in 1987. He
left his estate to two charitable foundations in Scottsbluff.
On December 23, 1988, Kosman, Inc., bought 1,140 shares of
Scottsbluff National Corp. stock from Helen Schwab for $456.29
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