- 19 - $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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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