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of Mr. Kleeman. We agree with, and therefore accept, Mr. Davis'
analysis. We do so for the following reasons:
First, Mr. Davis properly considered the relevant factors: (1)
The relative size of the Trust's block of stock in relationship to
the number of shares of stock outstanding, (2) the ownership of
other blocks of stock, (3) current and historical trading volumes
of shares of Applied Power stock, and (4) recent company-specific
events. Mr. Davis also reviewed general economic conditions and
securities market trends and sentiment.
Second, in determining the size of the blockage discount to be
applied, Mr. Davis tabulated information relating to eight 50,000-
share-plus-trading days of Applied Power common stock in 1993,
comparing the stock's closing price on each of those days with its
previous day's closing price, and noted that the largest down tick
trading day was 2.5 percent, whereas on one of the largest trading
volume days there was an up tick of 1.5 percent. On the basis of
this comparison, Mr. Davis concluded that only a modest blockage
discount would be appropriate.
We are mindful that as a general rule only facts known at the
valuation date are considered in determining the property's value.
However, subsequent market activities may provide helpful
comparable sales. See Estate of Newhouse v. Commissioner, 94 T.C.
193, 218 n.15 (1990). Here, we believe the three sales by the
Trust within 3-1/2 months of decedent's death to be relevant and
reasonably proximate to the valuation date. This 3-1/2-month
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