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date of decedent's death or the valuation date), and all Rule
references are to the Tax Court Rules of Practice and Procedure.
After settlement of some issues, the sole remaining issue
for decision is the fair market value, as of the date of
decedent's death, of 366,385 shares of common stock of a closely
held corporation.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time of decedent's death, decedent resided in
Amarillo, Texas. At the time the petition was filed, John H.
Marmaduke, the executor of decedent's estate, resided in
Amarillo, Texas.
Upon his death in 1993, decedent owned 366,385 shares or
approximately 22 percent of the total outstanding common stock in
Hastings Books, Music & Video, Inc. (Hastings). Other members of
the Marmaduke family owned another 957,685 shares or 57 percent
of the total outstanding common stock in Hastings. Together, the
Marmaduke family (including decedent's wife, children, and
grandchildren) owned 79 percent of the total common stock in
Hastings.
Shareholders unrelated to the Marmaduke family, comprising
Hastings employees and a qualified employee benefit plan covering
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