Doris F. Rabenhorst and Alvin P. Rabenhorst, Sr. - Page 4

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          for the 1988 stock transfer in the amount of $385.  Willis’                 
          computation is as follows:                                                  
               Capital                       $310,000                                 
               Special surplus               1,000                                    
               Unassigned surplus       5,579,972                                     
               Mandatory securities                                                   
               valuation reserve               636,475                                
               Subtotal                                     $6,527,447                
               Plus:                                                                  
               1.5 x annual premium income   2,659,323                                
          Subtotal                                          9,186,770                 
          Less:                                                                       
               35% discount                 3,215,370                                 
               Total discounted value                        5,971,400                
               Total discounted value       5,971,400                                 
               Divided by:                                                            
               Shares outstanding               15,500                                
               Discounted per-share value                        $385                 
               In October 1990, petitioners’ tax counsel complied with an             
          earlier request and provided an agent for respondent with a                 
          written explanation of Willis’ computation of the discounted per-           
          share value for the 1988 stock transfer.  The principal focus of            
          this correspondence concerned the 35-percent minority interest              
          discount factor and the addition of 1-1/2 years’ annual premium             
          income.                                                                     
               In 1992, in reaction to respondent’s having initiated an               
          examination of petitioners’ 1988 gift tax returns, petitioners’             
          tax counsel hired David B.H. Chaffe III (Chaffe), of Chaffe &               
          Associates, Inc., to conduct a second appraisal of RLIC and the             
          1988 stock transfer.  Chaffe’s appraisal report was provided to             





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