Estate of Frank A. Branson - Page 30




                                       - 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.                 




Page:  Previous  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  39  Next

Last modified: May 25, 2011