Estate of Frank A. Branson - Page 49




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               Finally, we reject the value Spiro obtained with his                   
          piecemeal sales method, because we think the method results in              
          the value of the stock to a particular borrower, not the fair               
          market value.                                                               
               We think that petitioner's sale of 135 shares at arm's                 
          length to unrelated parties after decedent's death provides the             
          best indication of the value of a minority interest in Willits.             
          In this transaction, the shares were purchased by persons whom we           
          presume have knowledge of the limits of the market and the value            
          of a minority interest in Willits.                                          
               Moreover, Willits shares have historically traded at or near           
          book value.  In petitioner's sale, the shares sold for                      
          approximately 2.9 percent less than their book value at the time            
          of sale.  The book value provided this Court nearest the date of            
          valuation was $806.  Accordingly, we find that the value of a               
          minority interest on the date of valuation was $783, before                 
          applying a discount for blockage.                                           
               The market for the Willits' shares was limited, and                    
          petitioner could not have sold its block of shares in a                     
          reasonable period of time without depressing the market and                 
          lowering the price.  Accordingly, we apply a 20-percent discount            
          for blockage and find that the fair market value of the Willits             
          stock is $626 per share.                                                    







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