Estate of W. Clyde Wright - Page 5

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          substantially all of the assets of the corporation may occur                 
          without approval of at least 66 2/3 percent of the shareholders.             
               On January 20, 1991, petitioner timely filed decedent’s                 
          Federal estate tax return, and, for purposes of valuing the                  
          201,408 shares of stock in Wilber Corp that decedent owned as of             
          the date of his death, petitioner elected to use on the estate               
          tax return the alternate valuation date of October 20, 1990.                 
          Petitioner attached to the Federal estate tax return a letter                
          prepared by Alex Sheshunoff & Co., Inc. (petitioner’s first                  
          expert), a national investment banking firm that maintains a                 
          division specializing in the appraisal of banks and bank stock,              
          in which this expert valued decedent’s 201,408 shares of stock in            
          Wilber Corp, after discounting for various factors, at                       
          $7,653,504, or $38 per share.                                                
               On audit, respondent obtained an appraisal of decedent's                
          201,408 shares of stock in Wilber Corp from Business Valuation               
          Services, Inc. (BVS).  Respondent's expert considered the same               
          basic factors used by petitioner's expert but applied a control              
          premium, valuing decedent's 201,408 shares of stock in Wilber                
          Corp at $13,562,815, or $67.34 per share.                                    

                                       OPINION                                         
               Fair market value is defined as the price at which property             
          would change hands between a willing buyer and a willing seller,             
          neither being under any compulsion to buy or sell and both having            





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