Estate of Dorothy B. Foote - Page 20




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          depth and trend as a whole (measured at and after the valuation              
          date).  See, e.g., Estate of Christie v. Commissioner, supra.                
               With the foregoing in mind, the stage is now set for our                
          consideration of the expert opinions offered by each of the parties          
          in support of their respective positions as to the blockage                  
          discount to be herein applied.                                               
          Petitioner's Expert                                                          
               Mr. Kleeman (the individual who wrote a July 1997 report                
          discussed supra p. 15) was petitioner's expert witness.  He has an           
          undergraduate degree in accounting, is a licensed certified public           
          accountant, and heads the business valuation practice of the                 
          accounting firm of Clifton Gunderson, L.L.C.  At the time of trial,          
          he held three business valuation designations (one each from the             
          American Institute of Certified Public Accountants, the American             
          Society of Appraisers, and the National Association of Certified             
          Valuation Analysts).                                                         
               Practically all of the 60 to 80 business valuation assignments          
          Mr. Kleeman prepares or reviews every year consist of valuations             
          concerning closely held companies. In addition to the work he                
          performed for petitioner, Mr. Kleeman participated in a few other            
          assignments involving the application of the blockage discount in            
          determining the value of publicly traded stock.                              
               Mr. Kleeman prepared his September 1998 report for purposes of          
          this trial.  He therein concluded that a 22.5-percent blockage               
          discount was appropriate in valuing the stock at issue, resulting            
          in a valuation of $11.72 per share or total of $3,288,000 for all            

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