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          of the same shares sold later in an IPO.  The study concluded               
          that the sales prices in the nonpublic markets were 40 to 45                
          percent less than sales prices in the IPO's.  Thus, Gasiorowski             
          concluded that the estimated marketable minority value, which he            
          implicitly assumes is equal to an IPO value, should be reduced by           
          45 percent to reflect the nonpublic market value of the shares.             
          We reject this conclusion for the following reasons.                        
               Petitioner offered no evidence that the value of the shares            
          was affected by any change in the market conditions, the                    
          constraints of the economy, or the financial condition of Savings           
          between the date of decedent's arm's-length sale of 1,111 shares            
          for $307 per share in the nonpublic market and the valuation date           
          1 month later.  Consequently, if we apply the conclusions of the            
          IPO study to the case at hand, we find that it is more likely               
          that $307 is 40 to 45 percent less, rather than more, than the              
          price at which the same shares would sell in an IPO.                        
               Furthermore, Gasiorowski disregards the fact that the actual           
          sales value of the shares is nearly identical to his estimated              
          marketable minority value.  The near identity of values indicates           
          that the marketability of the Savings shares in the nonpublic               
          market is essentially equal to that of a minority interest in the           
          public market, in which case no discount for marketability is               
          required for a minority interest in Savings.                                
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