Maude G. Furman, Donor, Deceased, and Estate of Maude G. Furman, Deceased, Robert G. Furman, Executor - Page 18

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               Robert was a key person in the management of FIC.  His                 
          potential absence or inability were risks that had a negative               
          impact on the fair market value of FIC.  On February 2, 1980, the           
          fair market value of each decedent's gratuitous transfer of 6               
          shares of FIC's common stock was subject to a key-person discount           
          of 10 percent.  On August 24, 1981, the fair market value of the            
          24 shares of FIC's common stock transferred by each decedent in             
          the Recapitalization was subject to a key-person discount of 10             
          percent.                                                                    
                             ULTIMATE FINDINGS OF FACT                                
               On February 2, 1980, the fair market value of the gratuitous           
          transfer of 6 shares of FIC's common stock by each of Maude and             
          Royal to Robert was $82,859 ($13,810 per share).                            
               On August 24, 1981, when Maude and Royal each exchanged 24             
          shares of FIC common stock for 3,000 shares of FIC's preferred              
          stock, the fair market value of the common stock transferred by             
          each of them was $424,552 ($17,690 per share).                              
                                       OPINION                                        
          A.   Fair Market Value of FIC Stock                                         
               Section 2501(a) provides for a tax on gifts by individuals.            
          Section 2512(a) provides that the value of a gift of property at            
          the date of the gift shall be considered the amount of the gift.            
               The principal issues we must decide in this case are the               
          value of the shares of common stock in FIC that decedents                   
          gratuitously transferred to Robert on February 2, 1980, and the             




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