Estate of Arthur G. Scanlan, Deceased, Ruth B. Scanlan, Administratrix - Page 6

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          guided by our common sense, knowledge, and experience.                             
          Petitioner's frustration with our memorandum opinion is best                       
          attributed to its inability to build a better record from which                    
          we could have made a more precise determination.  Petitioner                       
          chose to rely mainly on Mr. Chaffe to reach the end that it                        
          desired, and we found Mr. Chaffe's expertise to be of no                           
          important value.5                                                                  
                Accordingly, we decline to reconsider our memorandum                         
          opinion.                                                                           
                To reflect the foregoing,                                                    

                                                      An appropriate order will              
                                                 be issued denying petitioner's              
                                                 motion.                                     









                5 We also note that petitioner has never persuaded us that                   
          the shares were not marketable.  Even assuming arguendo that the                   
          shares were not readily marketable, a fact that we were unable to                  
          find, we had trouble concluding on the instant record that the                     
          shares were not marketable at all.  The marketability discount                     
          that we factored into the $50.50885 value set forth in our                         
          memorandum opinion at 1996-331 takes into account the absence of                   
          a recognized market for the subject stock, as well as the fact                     
          that a buyer may have to incur a subsequent expense to register                    
          the stock for public sale.  See Mandelbaum v. Commissioner,                        
          supra; Estate of Trenchard v. Commissioner, T.C. Memo. 1995-121.                   




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