Estate of Mario E. Bosca, Deceased, Marie A. Baker Formerly Marie A. Bosca, Executor - Page 19

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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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