- 30 -
for sale over 11 years.12 Furthermore, we have stated that
later-occurring events that evidence fair market value may be
taken into account. See Estate of Jung v. Commissioner, 101 T.C.
at 431; see also Estate of Newhouse v. Commissioner, 94 T.C. at
218 n.15. In estimating the number of shares that could be sold
per year, Gasiorowski did not consider petitioner's sale of 2,800
shares less than 10 months after the date of decedent's death.
Accordingly, we find little in Gasiorowski's methodology to
support his opinion of the length of time it would take to
dispose of petitioner's shares.
As an alternative to dribbling petitioner's shares into the
local market, Gasiorowski considered the consequences of
disposing the block in the public market. Gasiorowski
interviewed several experts who value closely held bank stocks
for their opinion of the price at which petitioner's stock would
trade if it were offered on the public market. The experts'
opinion was that the stock could be expected to trade at a price
ranging from 50 to 70 percent of book value, and most likely at a
12For instance, 228 shares changed hands in 1990, 1,534 in
1991, and 3,000 in 1992. The average number of shares sold per
year over this 3-year period is almost 7 times the number sold in
1990, and is about one-half the number of shares sold in 1992.
Thus, the average number of shares sold per year over the 3-year
period does not necessarily represent the number of shares sold
in any particular year, or by a willing seller at any time.
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