- 25 - ULTIMATE FINDINGS OF FACT 1. The class A voting stock is to be accorded a premium for its voting privileges. After giving consideration to the premium for the voting privileges, and after applying a 35-percent marketability (lack of liquidity) discount, the fair market value of decedent's class A voting stock was $215,539.01 per share or a total of $3,879,702.19, on the valuation date. 2. After applying a 40-percent marketability (lack of liquidity) discount, the fair market value of decedent's class B nonvoting stock was $3,417.05 per share or a total of $13,470,190.88, on the valuation date.3 3. Because there has been no payment of State transfer or inheritance taxes, respondent correctly did not include in the computation of the amount of the marital deduction (and in the computation of the asserted estate tax deficiency) an allowance for State transfer or inheritance taxes paid. 4. Petitioner acted reasonably and in good faith in relying on the advice of tax professionals and appraisers in valuing decedent's class A voting stock and class B nonvoting stock for Federal estate tax purposes. 3 In arriving at the valuations in Ultimate Findings of Fact Nos. 1 and 2, we did not consider certain exhibits (Exs. 22- J, 30-R, 41-J, 42-J, 43-J, 44-J, 45-J, 46-J, 121-P, 124-P, 125-P, 126-P, 127-P, and 128-P) that the parties objected to in the stipulations of facts. These documents are not probative and accordingly have been accorded no weight.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011