Estate of Frank A. Branson - Page 33




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          Spiro next considered the particular facts and circumstances of             
          the Savings stock, including the existing market for the stock,             
          the rising price trend of the traded shares, Savings' history of            
          paying increasing dividends, and the lack of restrictions on                
          trading the shares.  Spiro concluded that a liquidity discount of           
          20 percent was appropriate and that under the market method the             
          fair market value of the stock was $295.27 per share.                       
               To incorporate the actual sales value into his analysis, and           
          to reflect the amount of time it would take to sell a block of              
          shares the size of petitioner's, Spiro assumed that the                     
          shareholder could go to a lender and hypothecate the block for a            
          loan.  To repay the loan, the shareholder would sell the shares             
          over the next 8 years and 3 months at a rate equal to the number            
          of shares that were sold on average per month during the first 10           
          months of 1991.  Spiro estimated the prices for which the shares            
          would sell in future years by increasing the actual price at                
          which decedent sold 1,111 shares in 1991 by a factor that was a             
          conservative reflection of the historic growth rate of the                  
          stock's book value.  In this calculation, Spiro included his                
          estimation of the cash-flow from future dividends paid.  Finally,           
          Spiro assumed that the shareholder would pay 2 percentage points            
          above the prime rate, which was 7.5 percent at the date of                  
          valuation, for the loan.  Therefore, he calculated the present              







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