Estate of Frank M. DiSanto, Deceased, Roxanne DiSanto Tinnell, Byrnadette DiSanto, and Frank DiSanto, Coexecutors - Page 18




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          to estimate the value of MD&F stock in her husband's estate when            
          he died.  MPI considered MD&F’s declining net profits and the               
          outlook for the fabric processing business between the times when           
          Mr. and Mrs. DiSanto died.  MPI estimated that each share in a              
          minority block of 121,823 shares of MD&F stock had a fair market            
          value of $14.96 on November 26, 1992, and $13 on June 4, 1993.              
          The $1.96 difference per share multiplied by 121,823 shares                 
          equals $243,646.  Respondent's concession that MD&F stock                   
          declined in value by about $250,000 between the deaths of Mr. and           
          Mrs. DiSanto approximates MPI's estimate of the decline in value            
          of a minority interest in MD&F stock during that time.  We                  
          conclude that MPI’s estimate of the decline in value of MD&F                
          stock between the times Mr. and Mrs. DiSanto died is reasonable.            
               Petitioners speculate that the value of MD&F stock is lower            
          than MPI’s estimates.  Petitioners point out that Mr. DiSanto’s             
          estate had not transferred MD&F stock certificates to Mrs.                  
          DiSanto’s estate, and contend that it is possible that Mrs.                 
          DiSanto’s estate would never possess MD&F stock.  Petitioners               
          also speculate a buyer of MD&F stock from Mrs. DiSanto’s estate             
          might become liable for Mr. or Mrs. DiSanto’s estate taxes.  We             
          disagree.  There is no credible evidence that these factors may             
          affect the value of MD&F stock, or otherwise supporting                     
          petitioners' criticism of their expert's appraisals.                        
               Frazier estimated that Mrs. DiSanto’s interest in Mr.                  
          DiSanto’s estate was worth $447,327 (76,012 shares of MD&F x                




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