- 13 - 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 hadPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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