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of decedent's death, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
After settlement, the sole issue for decision is the value,
as of October 20, 1990 (the alternate valuation date), of 201,408
shares of common stock of the Wilber Corp. (Wilber Corp).
FINDINGS OF FACT
Many of the facts have been stipulated and are so found.
At the time of decedent's death, decedent resided in Otsego
County, New York. At the time the petition was filed, the
executor resided in Vestal, New York. Petitioner opted to use
the alternate valuation date of October 20, 1990, for purposes of
valuing decedent's stock in Wilber Corp.
At the time of his death, decedent owned 201,408 shares or
23.8 percent of the total 847,524 shares of common stock of
Wilber Corp. Wilber Corp holds 100 percent of the common stock
of Wilber National Bank (Wilber Bank or the bank). Wilber Bank
is a federally chartered bank. Wilber Corp’s stock is not listed
on any stock exchange but is traded infrequently on the over-the-
counter market.
The following schedule identifies, as of October 20, 1990,
the 10 largest shareholders of Wilber Corp, and for each
shareholder the number and percentage of shares owned:
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