- 5 - non-marketable, minority blocks of shares."5 Decedent’s Form 709 shows that the value of $34.84 per voting share as of April 12, 1991 (the date of the gift), was ascertained by: (1) Starting with a value of $30,500 per voting share as of August 31, 1989, as stated in the 1989 report, (2) adjusting that value for a 1000-for-1 stock split in June 1990, yielding a value of $30.50 per share, and (3) increasing the latter figure by $4.34, to reflect an increase in book value per voting share from December 31, 1989, until December 31, 1990. On February 1, 1992, a Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, was filed on petitioner’s behalf. Petitioner’s Form 706 reported the date-of-death value of Decedent's Eatel stock at $35.20 per share. This amount was based on a two-page valuation report of C & A, signed by Mr. Chaffe on October 21, 1991 (1991 report). C & A prepared the 1991 report by relying heavily on its 1989 report. The 1991 report also states that C & A: (1) Reviewed Eatel’s certified financial statements for its calendar years ended December 31, 1989 and 1990, as well as Eatel’s uncertified financial statements for the 7-month period ended July 31, 1991,6 (2) discussed with Eatel’s president Eatel’s past, present, and future business decisions, as well as the state of the 5 The 1989 report states that DATA has 21 shareholders. 6 C & A also looked at the relevant financial statements of Eatel’s subsidiaries.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011