Estate of Arthur G. Scanlan, Deceased, Ruth B. Scanlan, Administratrix - Page 8

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          1987, was $734,710.7  Eatel’s (or DATA’s, as the case may be)                      
          1988 through 1992 net income (after taxes) was $6,380,390,                         
          $4,015,870, $5,148,594, $5,491,633, and $6,587,602, respectively.                  
          Eatel paid dividends of $1 per share in 1990, $2 per share in                      
          1991, and $2.50 per share in 1992.  Neither Eatel nor DATA paid                    
          any dividends before August 31, 1989.8                                             
                There were no sales or redemptions of Eatel stock between                    
          1989 and 1994.                                                                     
                                          OPINION                                            
          1.  Relevancy                                                                      
                Before turning to the primary issue of valuation, we must                    
          decide a relevancy objection raised by petitioner (and submitted                   
          to and filed by the Court as a written motion) as to stipulations                  
          and other evidence relating to the:  (1) Offers in 1993 to                         
          purchase all of Eatel’s stock and (2) redemption of the Other                      
          Shareholders’ stock at $75.1555 per share.  Petitioner argues                      
          that this evidence (the disputed evidence) is irrelevant for                       
          purposes of determining value on the Valuation Dates because:                      
          (1) There were no agreements, offers, or negotiations on the                       
          Valuation Dates to sell all of Eatel’s stock or assets; (2) the                    

                7 The 6-month period stemmed from DATA’s change to the                       
          calendar year from a fiscal year ended June 30.  An income                         
          statement included in Exhibit 3 erroneously lists this 6-month                     
          period as ended on June 30, 1987.                                                  
                8 We are unable to determine Eatel’s net income (before                      
          taxes) or dividends for 1993 because the record does not reveal                    
          Eatel's financial data for that year.                                              




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