Estate of Frank M. DiSanto, Deceased, Roxanne DiSanto Tinnell, Byrnadette DiSanto, and Frank DiSanto, Coexecutors - Page 19




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          $5.88 per share).  Frazier used (a) a combination of the net                
          asset value and market approaches, (b) a combination of the                 
          income and market approaches, and (c) the Black-Scholes method,             
          and then applied various discounts.                                         
               We reject Frazier's estimate because he used the following             
          assumptions which are not supported by the record:  (a)                     
          Administrative expenses, estate taxes, and liabilities would                
          consume all of the liquid assets in Mr. DiSanto’s estate and some           
          of his MD&F stock; and (b) 45,811 shares of MD&F stock would have           
          to be sold at $13 per share to satisfy Mr. DiSanto’s estate’s               
          liabilities.                                                                
               3.   Conclusion                                                        
               We accept MPI’s estimate that the fair market value of Mrs.            
          DiSanto’s interest in Mr. DiSanto’s estate, that is, his MD&F               
          stock, was $13 per share on June 4, 1993.                                   
          C.   Marital Deduction for the Estate of Mr. DiSanto                        
               In computing the amount of the taxable estate, an estate may           
          deduct the value of interests which pass from a decedent to the             
          decedent's spouse (marital deduction).  See sec. 2056(a).                   
          Petitioners contend that the marital deduction for Mr. DiSanto’s            
          estate should be computed based on the value of the controlling             
          block of 186,177 shares of MD&F stock held by Mr. DiSanto, not              
          the value of the minority block to which Mrs. DiSanto was                   
          entitled after she executed the disclaimer.                                 






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