- 39 - 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 ofPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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