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Petitioners point the Court to the sales by Mr. Hoffman and
Ms. Branch and argue that these sales establish that the per-
share value of the estate's stock equaled the value at which
these sales were consummated; i.e., $29.70 per share.
Petitioners vehemently argue that these sales are the most
accurate measure of value because, petitioners state, both
sellers were knowledgeable persons who were under no compulsion
to sell.
We disagree with petitioners that either sale is indicative
of the value of the estate's stock. See Duncan Indus., Inc. v.
Commissioner, supra at 278. The estate's holdings were the
largest single ownership of Seminole stock by one person, and the
isolated sales relied upon by petitioners, which constituted
3.25- and 4.67-percent interests, are not sufficiently similar to
the estate's much larger 21.51-percent interest to make their
sale price representative of the value of the estate's stock.
Nor was either sale made by a person who was reasonably informed
on the date of sale as to the relevant facts surrounding the
value of the underlying property. Neither Mr. Hoffman nor Ms.
Branch performed any meaningful financial review as to the value
of his or her stock. Petitioners point the Court to the
affidavits of Mr. Hoffman and Ms. Branch, both of which were
prepared more than 2 years after the date on which Ms. Branch
sold her stock. In those affidavits, she and Mr. Hoffman assert
that they reviewed the Merrill Lynch report before selling their
stock. We find these assertions incredible. Merrill Lynch had
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