Charles C. Dockery, Donor - Page 13

                                        -13-                                          
          G.   Petitioner's Gifts of Crossroads' Stock                                
               On December 31, 1991, petitioner owned 9,600 of the 10,000             
          shares of common stock of Crossroads and all of the 750,000                 
          shares of preferred stock of Crossroads.  The remaining 400                 
          shares of the common stock were owned equally by Paula Dockery,             
          Mavis Dockery, Carl Dockery, and Michele Jones.  On January 1,              
          1992, and January 1, 1993, petitioner gave the following number             
          of shares of Crossroads' stock to his children:                             
               Donee               Date of gift        Common shares                  
          Carl Dockery             1/1/92                   448                       
          Michele Jones            1/1/92                   445                       
          Carl Dockery             1/1/93                   637                       
          Michele Jones            1/1/93                   637                       
          These shares represented a minority interest in Crossroads.                 
          H.   Gift Tax Returns and Notice of Deficiency                              
               Based on a June 22, 1992, appraisal by KPMG Peat Marwick,              
          petitioner reported on his 1992 and 1993 gift tax returns that              
          the fair market value of Crossroads' stock was $303 per share on            
          January 1, 1992, and January 1, 1993.  Petitioner paid gift tax             
          of $16,749 for 1993.                                                        
               Respondent determined that the fair market value of                    
          Crossroads' common stock was $704 per share on January 1, 1992,             
          and $1,010 per share on January 1, 1993.                                    
                                    II.  OPINION                                      
               The sole issue for decision is the fair market value of                
          Crossroads' stock that petitioner gave to his children on January           
          1, 1992, and January 1, 1993.                                               



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