-25-
Crossroads' common stock on the gift dates in the notice of deficiency.
KPMG Peat Marwick applied a 40-percent discount. Because we
found KPMG Peat Marwick's appraisal of Crossroads' stock
reliable, we adopt KPMG Peat Marwick's contention that a 40-
percent discount should be applied to value the Crossroads' stock
petitioner gave to his children in 1992 and 1993.
E. Conclusion
We conclude that the fair market value per share of the
stock of Crossroads that petitioner gave to his children was $303
per share on January 1, 1992, and $303 per share on January 1,
1993.
Decision will be entered
that there are no deficiencies
due from petitioner, and there
is no overpayment due to
petitioner.
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