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of Winkler v. Commissioner, T.C. Memo. 1989-231 (nonvoting shares
had less value than voting shares).
d. Summary of Discounts
The experts' opinions and our holding as to the discounts to
apply in valuing Kosman, Inc., stock that petitioner gave to her
children are as follows:
Petitioner's Respondent's
Discount Stock Expert Experts Holding
Minority Voting &
interest nonvoting
common 10 percent 10 percent 10 percent
Lack of Voting &
marketab. nonvoting
common 25 percent 10 percent 15 percent
Lack of Nonvoting 10 percent 4 percent 4 percent
voting common
power
6. Value of Kosman, Inc., Stock That Petitioner Gave to Her
Children
We conclude that the fair market value per share of the
stock of Kosman, Inc., that petitioner gave to her children was
as follows:
Voting Nonvoting
Stock Stock
September 30, 1986 $164.85 $156.06
March 31, 1987 185.58 175.69
To reflect the foregoing,
Decision will be entered
under Rule 155.
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