Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek - Page 30

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          net income of $877,770 in 1992.  Although Sterling's 1992 income            
          statement did not report this income until after the applicable             
          valuation date, it is reasonable to conclude under the facts                
          herein that Sterling had (or could have obtained) enough                    
          information on September 18, 1992, to ascertain that it would               
          report a significant amount of net income for that year.                    
               The fact that Sterling had not effectuated partial                     
          redemptions in 1991 or 1992 is also not controlling.  Redemptions           
          during those periods were based on a "best efforts" standard, and           
          Sterling's failure to redeem the Sterling preferred stock during            
          those years under the circumstances herein does not support a               
          finding that Sterling would have breached its obligation to                 
          effectuate the mandatory redemptions which were scheduled for               
          each December 31, 1993 through 1995.  Indeed, Sterling met its              
          obligation to redeem the decedent's Sterling preferred stock when           
          it redeemed all Sterling preferred stock on January 17, 1994.  We           
          will overrule the estate's relevancy objection to the                       
          admissibility of facts concerning the redemption.                           
               Turning to the valuation issue, special rules govern the               
          valuation of corporate stock.  When stock is listed on an                   
          established securities market, the stock's value usually equals             
          its listed market price.  When stock is not listed on such a                
          market, the stock's value may be based on arm's-length sales (if            
          any) that have occurred within a reasonable time of the valuation           





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