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On February 22, 1994, Bank One, on behalf of the Trust, sold
an additional 40,000 shares of the Trust's block of Applied Power
stock at $19.25 per share through Jefferies & Co., Inc.
(Jefferies), in one or more negotiated trade or trades. The
transaction results were reported on the NYSE. (The reported NYSE
high and low trading quotes for Applied Power on February 22, 1994,
were $19.375 per share and $19.125 per share, respectively.)
On March 11, 1994, Bank One, on behalf of the Trust, sold the
balance of the Trust's block of stock (40,507 shares) at $19.50 per
share through Jefferies, in one or more negotiated trade or trades.
The transaction results were reported on the NYSE. (The reported
NYSE high and low trading quotes for Applied Power on March 11,
1994, were $19.875 per share and $18.75 per share, respectively.3)
Estate Tax Return, Notice of Deficiency, and Petition
On Schedule G of its estate tax return (filed November 8,
1994), petitioner valued the 280,507 Applied Power shares in
question as of decedent's date of death at $4,020,600.24, or
$14.333 per share, claiming a blockage discount of $0.792 per
3 The table below summarizes the Trust's 1994 sales of its
Applied Power shares:
Applied Price Previous
Trade Total Shares Per Day
Date Volume Sold Share High Low Close Close
2/17 256,400 200,000 $19.000 $19.250 $19.000 $19.125 $19.125
2/22 40,800 40,000 19.250 19.375 19.125 19.125 19.125
3/11 76,200 40,507 19.500 19.875 18.750 19.625 18.250
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