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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
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