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market's appreciation of the value of a minority interest in
Savings stock and its awareness of the stock's limited
marketability.
Moreover, no evidence was offered of any change in the
market conditions, the constraints of the economy, or the
financial condition of Savings between the date of decedent's
sale of 1,111 shares and the date of petitioner's sale of 2,800
shares that would have affected the demand for the shares. Thus,
the fact that decedent's block of shares sold quickly once it was
offered, and that approximately 10 months later petitioner's
larger block of shares sold equally quickly, indicates that the
market for Savings' shares is considerably more liquid than
either petitioner or respondent opined.
However, although Mannon testified that after petitioner's
sale some of the buyers expressed an interest in purchasing more
shares, he also testified that others could have bought no more.
Furthermore, although the blocks of stock sold by decedent and
petitioner sold quickly and the shares in petitioner's sale sold
for a higher price than the shares in decedent's earlier sale,
the amount by which the actual sales price exceeded book value
was slightly less in the later sale than in the earlier sale.21
21Decedent sold 1,111 shares at 8.31 percent above book
value; petitioner sold 2,800 shares at 4.12 percent above book
value.
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