Charles C. Dockery, Donor - Page 25

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          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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