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company, rated Wilber Bank as having the highest estimated 1990
earnings per share and the second highest estimated 1990 dividend
payment per share of any upstate New York commercial bank. Out
of the upstate New York commercial banks, the First Albany report
recommended that investors purchase shares of stock in four banks
or bank holding companies, one of which was Wilber Corp.
In the instant case, shares of stock in Wilber Corp were
traded in small quantities in the over-the-counter market on and
around the valuation date, at a price of approximately $50 per
share. Both parties' experts appear to have used this figure as
a starting point in valuing decedent's 201,408 shares of stock in
Wilber Corp.
Petitioner's first expert valued the shares of stock in
Wilber Corp at $7,653,504, or $38 per share. Petitioner’s expert
utilized: (1) The comparable market approach to valuation,
comparing Wilber Corp's book value, earnings per share, price-to-
book-value ratio, adjusted book value, and adjusted earnings with
those of similarly sized, publicly traded banks and bank holding
companies, and (2) the income or investment value approach to
valuation, calculating the net present value and future earnings
of Wilber Corp and the return on investment using a 12-percent
rate of return. Also, although the size of the block of stock
was considered and taken into account in arriving at a value of
$38 per share, petitioner's first expert testified that he did
not factor in a specific and separate discount or premium
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