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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.
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