Estate of Helen J. Smith, Deceased, Frederic L. Foill II and Cassandra F. Vallery, Co-Executors - Page 4




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          FNBW                                                                        
               FNBW was a corporation that operated a bank in Pike County,            
          Ohio, that had been in decedent’s family for many years.  On the            
          date of decedent’s death, there were 100,000 shares of FNBW                 
          outstanding and 95 shareholders.  Decedent owned 12,000 shares in           
          FNBW when she died.  On December 31, 1992, 25 days before                   
          decedent’s death, FNBW’s total assets were $103,884,000 and total           
          stockholder equity was $11,249,000.  In the period from 1988                
          through 1992, FNBW’s earnings increased each year from $917,000             
          in 1988 to $1,423,000 in 1992.  In the same period, its dividends           
          also increased each year from $348,000 in 1988 to $640,000 in               
          1992.                                                                       
               On the estate tax return, petitioner claimed a value for               
          decedent’s shares in FNBW of $73.67 per share.  In the notice of            
          deficiency, respondent valued decedent’s shares in FNBW at                  
          $159.53 per share.                                                          
                              ULTIMATE FINDING OF FACT                                
               The fair market value of decedent’s 12,000 shares in FNBW at           
          the date of decedent’s death was $98 per share, or a total of               
          $1,176,000.                                                                 
                                       OPINION                                        
               We must decide the fair market value of decedent’s shares of           
          stock in JFI and FNBW on the date of decedent’s death on                    
          January 25, 1993.  Both parties rely upon expert opinions.                  






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