-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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Last modified: May 25, 2011