- 16 - obtaining the median discount, he selected a value such that half the discounts in his selected cases fell above that value and half below.) In the notice of deficiency mailed on October 15, 1997, respondent determined, in pertinent part, that the reported value of the Applied Power stock owned by the Trust was understated. Respondent determined that the blockage discount should be $0.125 per share (representing a 0.83-percent discount from the mean between the highest and lowest quoted selling prices applicable to the date of death) rather than $0.792 per share as claimed by the estate on the return. On October 29, 1997, the estate's co-personal representatives filed an amended estate tax return requesting a refund (on Form 843) of $352,799.99, in light of the Emory and July 1997 Kleeman reports. The personal representatives determined that the fair market value for the 280,507 shares in issue was $3,288,000, based on an $11.72 per-share valuation. In reaching this valuation, the personal representatives determined that a $3.405 per-share blockage discount (representing a 22.5-percent discount from the mean between the highest and lowest quoted selling prices applicable to the date of death) was appropriate. The July 1997 Kleeman report was attached to the amended return in order to substantiate the estate's position. ULTIMATE FINDING OF FACT The value of the Trust's 280,507 shares of common stock on the valuation date was $4,102,414.88, or $14.625 per share. ThisPage: 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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