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            valuing Kosman, Inc.'s Scottsbluff National Corp. stock.                                      
            Respondent's experts concluded that the fair market value of                                  
            Kosman, Inc.'s 32.085 percent stock interest in Scottsbluff                                   
            National Corp. was $4,663,555 on September 30, 1986, and                                      
            March 31, 1987.                                                                               
                  c.    Analysis:  Value of Kosman, Inc.'s Scottsbluff National                           
                        Corp. Stock                                                                       
                  Petitioner's expert acknowledged that Scottsbluff National                              
            Corp. was in better financial condition than First Commerce, the                              
            company he considered to be most comparable.  Petitioner's expert                             
            estimated that First Commerce stock sold at 57.7 percent of its                               
            book value per share on September 30, 1986, and March 31, 1987.                               
            Petitioner's expert concluded that shares of Scottsbluff National                             
            Corp. stock would sell at 60 percent of book value per share.  We                             
            believe that 60 percent is too low, considering Scottsbluff                                   
            National Corp.'s better financial condition.                                                  
                  Petitioner's expert said that by September 30, 1986, the                                
            investing public thought the northwestern Nebraska economy might                              
            improve soon.  Petitioner's expert noted that from mid-1985 to                                
            September 30, 1986, the price of First Commerce stock increased                               
            76 percent from $7.50 per share to $13.25 per share.                                          
                  Respondent's experts used as comparables four non-Nebraska                              
            bank holding companies, including Mark Twain Bancshares in                                    
            St. Louis, Missouri.  Respondent's experts did not adequately                                 
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