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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 in
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