Walter L. Gross, Jr., and Barbara H. Gross - Page 32




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          and he used G&J's real borrowing costs to derive an appropriate              
          cost of debt capital for G&J as of the valuation date.  Indeed,              
          G&J's 8.25-percent borrowing rate in 1991 was three-quarters of a            
          percent below the prime rate.  By the valuation date, the prime              
          rate had dropped to 6 percent; therefore we believe that                     
          Dr. Bajaj's opinion errs on the generous side, if at all.  We                
          accord significant weight to Bajaj's opinion.                                
               Further, the category immediately above "Very Small Cap.                
          Companies" in Mr. McCoy's rankings is entitled "Small Cap.                   
          Companies", which, according to McCoy, has a reported required               
          rate of return of 15 percent.  That figure is associated with a              
          nominal category that is not inconsistent with petitioners'                  
          assertions (that G&J was a "small company"), and it is in harmony            
          with respondent's asserted value.  Therefore, we conclude that an            
          appropriate cost of equity capital for G&J on the gift date was              
          15.5 percent.                                                                
          V.  Conclusion                                                               
               For the foregoing reasons, we conclude that the value of the            
          gifted shares on the gift date was $10,910 per share.                        

                                                   Decisions will be entered           
                                              under Rule 155.                          









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