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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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