Walter L. Gross, Jr., and Barbara H. Gross - Page 7




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          represented 0.95 percent of the issued and outstanding shares in             
          G&J.  Patricia and Calvin Linnemann (the Linnemanns) each                    
          reported one-half of the amount they determined to be the value              
          of the Linnemann gifts on a timely filed Form 709.  In                       
          determining (and reporting) the values of the Patricia Linnemann             
          gifts, the Linnemanns also relied on the Business Valuations                 
          report.  The total reported value of the Patricia Linnemann gifts            
          was $2,130,000.                                                              
                               ULTIMATE FINDING OF FACT                                
               On July 31, 1992, the fair market value of a share of stock             
          of G&J representative of the shares constituting both the Walter             
          Gross and Patricia Linnemann gifts was $10,910.                              
                                       OPINION                                         
          I.  Introduction                                                             
               On July 31, 1992, Walter Gross and Patricia Linnemann made              
          gifts to their respective children of shares of stock in a                   
          corporation, G&J Pepsi-Cola Bottlers, Inc. (G&J).  Walter Gross              
          and Patricia Linnemann are members of a family group (the Gross              
          family group) that, in 1992, owned 50 percent of the outstanding             
          shares of stock of G&J.  Each child received a number of shares              
          of stock in G&J constituting less than a 1-percent interest in               
          the corporation.  The parties disagree as to the fair market                 
          value (value) of those gifts.  The parties have assumed that each            
          of the shares of stock in question (a G&J share) had the same                





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