Estate of Sam Homer Marmaduke - Page 8




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          in the 1993 transactions involving Hastings stock, petitioner's             
          first expert entirely rejects the transaction method.                       
               Petitioner's second expert, using a 40-percent lack-of-                
          marketability discount, values the shares of decedent's stock in            
          Hastings at $12,658,602, or $34.55 per share.  Petitioner's                 
          second expert relies solely on the guideline company and                    
          discounted cash-flow methods while rejecting the transaction and            
          other valuation methods as inappropriate indicators of value.               
               Respondent's expert, using a 15-percent lack-of-                       
          marketability discount, values decedent's shares of stock at                
          $17,220,095, or $47 per share.  Respondent's expert utilizes the            
          guideline company, the discounted cash-flow, and the transaction            
          methods of valuation.                                                       
               In the schedule below, we summarize the total equity value             
          of the Hastings corporation, the discount for lack of                       
          marketability, and the per-share value of the Hastings stock as             
          reflected in the 1993 A.G. Edwards' report and in the reports of            
          the parties' expert witnesses.  With regard to the A.G. Edwards'            
          report, in the schedule we reflect separately the indicated value           
          for the Hastings shares of stock owned in general and for those             
          stocks held by the ESOP.1                                                   


         1  At trial and on brief, neither party relies on the $36.53                 
         per-share value of decedent's Hastings stock reflected on                    
         decedent's Federal estate tax return.  Accordingly, we do not                
                                                             (continued...)           





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