Cameron W. Bommer Revocable Trust, Ronald Bommer, Trustee - Page 32

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                  We are also unpersuaded that decedent was anticipating a                              
            decline in value.  There is no credible evidence suggesting that                            
            CamVic's value was declining at the time the original Buy-Sell                              
            Agreement was executed in 1975 or in 1981.  Indeed, valuations of                           
            CamVic stock made between 1969 and 1974 indicate that CamVic's value                        
            was actually increasing during this time.  On a gift tax return                             
            filed January 8, 1969, decedent reported the value of 9 shares of                           
            CamVic stock that he had gifted to Ronald at $7,091.07 per share.                           
            When CamVic later merged on June 21, 1971, with two other                                   
            corporations owned by the Bommer family, the value of CamVic's stock                        
            for purposes of computing the exchange ratio for the merger was                             
            $14,192.45 per share.  In addition, between 1972 and 1974, decedent                         
            made several gifts of CamVic stock to Ronald and his grandchildren.                         
            Each gift was valued for gift tax purposes at $15,105.74 per share.22                       
                  Second, an inference of testamentary device can be drawn from                         
            the manner in which the parties selected the $11,333.30 price per                           
            share for the purchase of CamVic stock.  Decedent was an experienced                        
            businessman, yet he failed to obtain a professional appraisal of                            
            CamVic, its subsidiaries, or its real properties.  Instead, decedent                        
            did nothing more than consult with his attorney Mr. Hughes.                                 
            Decedent and Ronald had one meeting with Mr. Hughes, who completed                          
            his computation, upon which the above price per share was based, in                         

                  22With respect to the period from 1975 until approximately                            
            April 1981, when the Revised Agreement was executed, CamVic's                               
            increasing value is not disputed by petitioners or their expert                             
            witness.                                                                                    




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