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Decedent Appraisal, however, makes express reference to the John
Appraisal and its conclusions.
On December 21, 1992, Northern Trust filed decedent's
estate’s Form 706 and reported on Schedule B thereof that on her
date of death decedent owned 79,730 shares of Johnco common stock
(a 96-percent interest), after taking into account the unified
credit bequest. The number of shares so reported was computed on
the assumption that on John’s date of death, the 82,865 shares
held by him had a value of $3.7 million, or $44.65 per share.
The $44.65 per share value was based upon the John Appraisal and
was utilized notwithstanding the fact that John’s date-of-death
value for such stock was reported on John’s Form 706 as $86.80
per share, or $7,192,967 for 82,865 shares. The Form 706 filed
by John’s estate has not been amended. The Estate further
assumed, apparently based on additional information regarding
John’s lifetime gifts, that Andrew's share of the unified credit
bequest was equal to $140,000, and funding this amount with
Johnco stock at an assumed value of $44.65 per share would
require 3,135 shares, leaving 79,730 shares in the Estate.
Relying on the Decedent Appraisal, the Estate reported the
value of the 79,730 shares on decedent's date of death as $3.5
million ($43.90 per share). According to the Decedent Appraisal,
Johnco had a liquidation value of $4.2 million, and 96 percent of
Johnco's common stock, after reduction to reflect minority
shareholder discounts (of approximately 13 percent), was worth
$3.5 million on decedent’s date of death.
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Last modified: May 25, 2011