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stock immediately after the recapitalization on May 25,
1990, was $9,415, if the share was part of a block of stock
amounting to either 50 or 25 percent of the outstanding
stock of the corporation.
The Decedent's Death
The decedent died on September 5, 1990. At the time
of his death, he held 695 shares of class B nonvoting
common stock in HBC. The fair market value of each share
of class B nonvoting common stock at that time was $8,843
per share. Thus, the value of the decedent's stock in HBC
at the time of his death was $6,145,885 ($8,843 x 695).
On October 1, 1990, the shareholders of HBC elected
Ms. Marie Baker, Mr. Christopher Bosca, and Mr. Anthony
Bosca as directors. On the same day, the board of
directors elected Mr. Christopher Bosca president,
Mr. Anthony Bosca vice president and treasurer, and
Ms. Marie Baker secretary.
The Decedent's Gift and Estate Tax Returns
Ms. Marie Baker, acting in her capacity as executrix
of the decedent's estate, filed Form 709, United States
Gift (and Generation-Skipping Transfer) Tax Return, for
the 1990 calendar year. A supplement to Schedule A,
Computation of Taxable Gifts, attached to the return states
as follows:
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