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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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