Estate of Frank A. Branson - Page 24




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               However, before reaching a definite conclusion of the                  
          stock's value, Gasiorowski interviewed several experts who value            
          closely held bank stocks.  From his discussions with these                  
          experts, Gasiorowski concluded that if a block of stock of the              
          size held by petitioner were publicly traded, it most likely                
          would trade at 55 to 60 percent of book value.  Applying this               
          discount to the October 31, 1991, book value of the Savings stock           
          suggested a public market value of $156 to $170 per share.  Thus,           
          Gasiorowski concluded that the date-of-death fair market value of           
          petitioner's shares was $170 per share.  We do not find                     
          petitioner's opinion persuasive.                                            
          Discounts for a Minority Interest and Lack of Marketability                 
               A minority interest discount reflects the minority                     
          shareholder's inability to compel either the payment of dividends           
          or liquidation in order to realize a pro rata share of a                    
          corporation's net earnings or net asset value.  A lack of                   
          marketability discount reflects the fact that there is no ready             
          market for shares in a closely held corporation.  Thus, discounts           
          for a minority interest and for lack of marketability are                   
          conceptually distinct, and the appropriate percentage rate of               
          each of them is a question of fact.  See Estate of Newhouse v.              
          Commissioner, 94 T.C. at 249.  Gasiorowski concluded that if the            
          stock were publicly traded, the value of a minority interest                
          would be $310 per share.  This estimated value reflects the                 





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