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b. Stock Transactions
There was no regular market for Peoples common stock, and
transfers were infrequent. On the valuation date, Peoples did
not have an employee stock ownership plan nor any history of
repurchasing shares. Within the 24 months before and after the
valuation date, there was only one arm's-length sale of Peoples
stock. In that transaction, which occurred after the decedent's
death, in 1994, Julia Raibley, assistant secretary of Peoples,
purchased 3 shares at $800 per share from the Stone estate. In
February 1990, after being named to the board, Victor Bowden
purchased 10 shares from the Toole Estate in order to comply with
the requirement in Peoples' bylaws that members of the board own
at least 10 shares of Peoples stock. Mr. Bowden purchased the
shares for $700 per share using funds he borrowed from decedent.
Also in February 1990, the Toole Estate sold 35 Peoples shares to
Mark for $700 per share.4
In June 1990, decedent transferred by gift 2 shares of
Peoples stock to Mark, reducing his interest in Peoples from
1,501 shares (50.03 percent) to 1,499 shares (49.97 percent).
The only reason given by decedent to Mark for the gift was to
"round off" Mark's holdings from 83 shares to 85 shares. Mark
4 The fair market value per share for Peoples stock reported
on the Form 706, United States Estate (and Generation-
Skipping Transfer) Tax Return, of the Ella Wright Estate in
1989 or 1990 was also $700.
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Last modified: May 25, 2011