Estate of Ann H. Brookshire, Deceased, Harvey B. King, Independent Executor - Page 6

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               For at least each of the 10 years prior to decedent’s death,           
          Brookshire paid cash dividends to its shareholders.                         
               On November 20, 1993, the date of decedent’s death -- based            
          on an approximate total book value for Brookshire of $164,764,000           
          -- the per-share formula price under the buy-sell and stock-                
          purchase agreements for the shares of Brookshire common stock               
          owned by decedent’s estate was $73.43 per share.                            
               Prior to decedent's death, no blocks of Brookshire common              
          stock anywhere near as large as decedent's block of 219,710                 
          shares had been sold.  In fact, in the 3 years prior to                     
          decedent’s death, the largest block of Brookshire common stock              
          that had been sold consisted of 6,111 shares.  Prior to                     
          decedent’s date of death, it appears that each sale of Brookshire           
          stock constituted a non-arm’s-length sale.                                  
               On August 22, 1994, decedent’s estate sold 29,410 shares of            
          Brookshire common stock back to Brookshire for $79.50 per share             
          in order to provide cash to the estate for payment of decedent’s            
          reported estate tax liability.                                              
               On August 23, 1994, petitioner timely filed decedent's                 
          Federal estate tax return.  Based on an appraisal, the total                
          value of the 219,710 shares of Brookshire common stock owned                
          directly and indirectly by decedent’s estate was reported on the            
          estate tax return at $12,907,962 or $58.75 per share.                       







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