- 20 - We start with the redemption price of $75.1555 because we believe that it represents the arm’s-length value for all of Eatel’s stock in August 1993. We adjust this price to account for the passage of time, as well as the change in the setting from the date of Decedent’s death to the date of the redemption agreement. We also adjust this price to take into account the marketability and minority discounts. In an ideal world, these two discounts are computed separately, as are the alterations for the change in setting. See Snyder v. Commissioner, 93 T.C. at 539. In the confines of our imperfect record, however, we are unable to determine these discounts with any specificity and choose to account for them and the other factors in the aggregate. Based on the record, and with the benefit of our common sense, knowledge, and experience, we find and conclude that the redemption price must be reduced by 30 percent to reflect the value of the subject shares on the date of Decedent’s death. Accordingly, we hold that the date-of-death value is $50.50885 per share. We find no material alteration in the value of the shares between the date of the gift and the date of death. Thus we find that the date-of-gift value equals the date-of-death value. Accordingly, we hold that the date-of-gift value is $50.50885 per share.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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