Estate of Arthur G. Scanlan, Deceased, Ruth B. Scanlan, Administratrix - Page 20

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                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.                                                                             







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