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one-half by each spouse. Respondent initially determined that
each share of stock in question had a value of $11,738, but now
concedes that each such share has a value of no more than
$10,910. Petitioners based their gift tax liabilities on a value
of $5,680, which they maintain is the correct value.
FINDINGS OF FACT
Introduction
Some of the facts have been stipulated and are so found.
The stipulation of facts, with accompanying exhibits, is
incorporated herein by this reference. At the time of the filing
of the petitions, all of the petitioners resided in Cincinnati,
Ohio.
G&J Pepsi-Cola Bottlers, Inc.
The shares of stock in question are shares of G&J Pepsi-Cola
Bottlers, Inc. (G&J), an Ohio corporation formed in 1969. The
business operations of G&J can be traced to a business conducted
by a partnership formed in the 1920s between two married couples,
Isaac N. and Esther M. Jarson and Walter L. and Nell R. Gross
(the founders). By 1992 (the year of the gifts here in
question), the founders had died, and ownership of G&J had
devolved to certain relatives of the founders, viz, the Gross
family group (which included members of the Linnemann family) and
the Jarson family group. In 1992, directly and through voting
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