- 4 -
totaling $22,630. On that date, B&W Longview had total liabili-
ties of $253,166 and equity of $2,168,839 consisting of $100,000
of capital stock, $9,412 of paid-in capital, and $2,059,427 of
retained earnings. The book value of B&W Longview on the valua-
tion date was $2,168,839.
Prior to the valuation date, decedent participated in the
following transactions involving corporations in which he had an
interest and which had portfolios of business loans that were
similar to B&W Longview's trade notes receivable:3 (1) The
purchase during 1987 (Young transaction) by decedent from Tommy
Young (Mr. Young) of Mr. Young's 50-percent stock interest in
TA&T Finance Corporation (TA&T Finance); (2) the purchase during
1989 (B&W El Paso transaction) by an unidentified individual from
decedent of decedent's 100-percent stock interest in B&W El Paso
(B&W El Paso); and (3) the purchases during 1991 (FNFS transac-
tion) by FNFS, Inc. (FNFS), from decedent of decedent's respec-
tive 100-percent stock interests in five corporations. (We shall
sometimes refer collectively to the foregoing transactions as the
precedent transactions.)
In the Young transaction, decedent, who owned 50 percent of
the stock of TA&T Finance, purchased during 1987 Mr. Young's 50-
percent stock interest in that corporation, thereby resulting in
3 Hereinafter, we shall also refer to the respective portfolios
of loans held by the corporations involved in the transactions in
question as trade notes receivable.
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