- 34 - Thus, the language of the stock plan itself suggests that the initial purchase price of $60.98 per share was less than the fair market value of the stock at the time the stock plan was adopted. Further, petitioner himself testified at trial that he believed the value of SWI increased at the moment he joined the company. Because petitioner purchased the subject stock after he officially joined the company, the value of the stock was, by his own admission, greater than it was at the time the $60.98 price per share was established. Thus, we find that the price of $60.98 per share established in the original acquisition transaction and the Share Compensation Plan does not provide an accurate measurement of the value of the stock. Events occurring after the valuation date provide additional evidence that petitioner's stock in SWI was worth more than $60.98 per share on June 30, 1989. First, in a letter dated June 14, 1990, KPMG Peat Marwick valued a noncontrolling interest in SWI at $2,500 to $2,700 per share as of March 31, 1990, only 9 months after the valuation date. Second, in a confidential private placement memorandum, Goldman Sachs & Co. and Alex. Brown & Sons, Inc., determined this value to be approximately $15,000 per share as of October 1, 1990.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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