- 19 - part of a 50-percent block of stock Value of a share of class B nonvoting$14,559 1$9,415 common stock after the recapitalization if held as part of a 50- or 25- percent block of stock Difference $4,368 $2,412 Number of shares 402.5 402.5 Aggregate value of gifts made $1,758,120 $970,830 by the decedent to his sons 1Stipulated by the parties. We note that neither party contends that the special valuation rules of sections 2701 through 2704 apply to the decedent's transfer that is the subject of these cases. See Omnibus Budget Reconciliation Act of 1990, Pub. L. 101- 508, sec. 11602(a), 104 Stat. 1388-491. Petitioner argues that by exchanging his voting common stock in HBC for class B nonvoting common stock, the only thing the decedent gave up in the recapitalization was the right to vote his 402.5 shares of stock in HBC. In this connection, petitioner emphasizes that the recapitalization effected no change in the assets, liabilities, or share- holders equity of HBC, either in the absolute or relatively among the shareholders. Thus, according to petitioner, the decedent did not suffer any loss or reduction of his interest in the shareholders equity of HBC. It follows, according to petitioner, that the decedent made no gift inPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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