-15-
voting and nonvoting) stock, and about 2.73 percent of the total
nonvoting common stock.
Rock Hill stock and Home stock were not registered or traded
on the New York Stock Exchange, the American Stock Exchange,
NASDAQ, over the counter, or listed in National Quotation Bureau
price reports (the pink sheets).
E. Petitioners' Gift Tax Returns and the Notices of Deficiency
The Helmlys each agreed to treat each of their gifts as
being made one-half by the other under section 2513. Mary Ann
and Frank Barnes, Louise and Edwin Barnes, and Jean and John
Barnes also elected to split their gifts under section 2513.
AUS Consultants, Valuation Services Group (AUS),6 estimated
that the fair market value of Home's common stock was $230 in
1992. Based on that estimate, the Helmlys each reported on their
1992 gift tax returns that the fair market value of Home's stock
was $230 per share.
AUS estimated that the fair market value of Rock Hill's
nonvoting common stock was $220 on December 1, 1992. Based on
that estimate, Frank and Mary Anne Barnes each reported on their
1992 gift tax returns that the fair market value of Rock Hill's
stock was $220 per share, and Louise and Edwin Barnes and John
6 The AUS appraisals were admitted into evidence for the
limited purpose of showing that they were sources of the factual
descriptions of Home and Rock Hill used in the report prepared by
respondent's expert.
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