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should be applied in valuing decedent's 50-percent stock interest
in B&W Longview. Although Mr. Harrell specified that he would
apply a 10-percent discount, Mr. Bernstein did not specify how
much of the 35-percent combined discount that he applied was
attributable to the fact that decedent did not own a controlling
stock interest in B&W Longview on the valuation date. On brief,
petitioner, who has the burden of proof, does not insist that a
minority discount in excess of 10 percent be applied in this
case.
Respondent contends, and petitioner disputes, that, because
the precedent transactions on which both experts, inter alia,
relied involved stock for which there was no ready market, the
respective prices paid for the stock sold in those transactions
reflected some lack-of-marketability discount. While we gener-
ally agree with respondent, it is significant that the stock
interests acquired in the precedent transactions were different
from decedent's 50-percent stock interest in B&W Longview in that
(1) the respective purchasers in the transactions involving
(a) B&W El Paso and (b) B&W Brownsville, B&W Harlingen, B&W
Mission, B&W Austin, and B&W Finance acquired 100 percent of the
stock of each of those corporations; and (2) although decedent
purchased only 50 percent of the stock of TA&T Finance in the
Young transaction, after that purchase, decedent owned 100
percent of the stock of that corporation. On the record before
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