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Therefore, the number of Savings shares that can be sold without
affecting price is uncertain, but not unlimited.
The facts and circumstances of this case indicate that a 10-
percent discount for blockage is appropriate. Accordingly, we
find that the fair market value of petitioner's Savings stock is
$276 per share.
Issue 2. Fair Market Value of the Willits Shares
Respondent determined that the value of petitioner's Willits
stock was $850 per share; however, he now contends that the date-
of-death fair market value of petitioner's Willits stock is $774
per share. Respondent bases his contention on the results of
petitioner's sale of all its shares approximately 9 months after
decedent's death.
Petitioner asserts that the value of the stock is $485 per
share, but concedes on brief that the evidence supports a
valuation in the range of $485 to $662 per share. Petitioner
further asserts that the sales history of Willits' stock is
evidence that there is no market for the shares, and that the
price it received for the shares is not representative of their
fair market value because the shares were not sold at arm's
length.
Petitioner sold its 500 shares of Willits stock for $850 per
share; 365 of the shares were purchased by Mannon. At the time
he purchased the shares, Mannon owned more than 30 percent of
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