Estate of Artemus D. Davis, Deceased, Robert D. Davis, Personal Representative - Page 24

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              Petitioner and all of the experts, including respondent's               
          expert, agree that, in determining the fair market value on the             
          valuation date of each of the two blocks of ADDI&C stock at issue,          
          it is necessary to reduce ADDI&C's net asset value on that date by          
          applying a discount or adjustment attributable to ADDI&C's built-           
          in capital gains tax.  However, there are disagreements as to the           
          amount of such a discount or adjustment.  In addition, petitioner           
          and petitioner's expert Mr. Howard disagree with petitioner's               
          expert Mr. Pratt and respondent's expert Mr. Thomson as to the              
          point at which such a discount or adjustment should be taken into           
          account in the valuation process.  Petitioner and petitioner's              
          expert Mr. Howard believe that, in calculating ADDI&C's net asset           
          value on the valuation date, the full amount of ADDI&C's built-in-          
          capital gains tax should be subtracted before any minority and              
          lack-of-marketability discounts are applied.  Petitioner's expert           
          Mr. Pratt and respondent's expert Mr. Thomson believe that a 15-            
          percent discount or adjustment attributable to ADDI&C's built-in            
          capital gains tax should be taken into account as part of the               
          lack-of-marketability discount that each agrees should be applied           
          to ADDI&C's net asset value on the valuation date after that net            
          asset value has been reduced by a minority discount.  Of the 50             
          percent lack-of-marketability discount equal to $29,254,391 that            
          Mr. Pratt determined should be applied, $8,776,317 is attributable          
          to ADDI&C's built-in capital gains tax.  Of the 38-percent lack-            
          of-marketability discount equal to $26,798,906 that Mr. Thomson             




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