Estate of Charles a. Boratello, Deceased, C. Norman Borgatello and Josephine E. Donnelly, Co-Executors, and C. Norman Borgatello, Successor Trustee to the Charles A. Borgatello Living Trust - Page 27

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            part and revd. and remanded in part on another ground 976 F.2d                             
            1163 (8th Cir. 1992), we stated:                                                           
                        The values arrived at by * * * [the expert] were                               
                  the basis for the date of death values of the corporate                              
                  properties.  * * *  Because in appraising the                                        
                  properties * * * [the expert] took into account the                                  
                  market for such property, as well as general economic                                
                  conditions in Grand Forks, the fair market value of                                  
                  Vaberg's corporate assets, and therefore the fair                                    
                  market value of 100 percent of the Vaberg stock, has                                 
                  already been adjusted for such conditions.                                           
                        To the extent that the market for residential real                             
                  estate and general economic conditions would have a                                  
                  negative impact on the fair market value of the 26.92                                
                  percent of Vaberg stock held by the decedent,                                        
                  petitioner has already reduced the reported value of                                 
                  the stock on account of such impact.  For this Court to                              
                  adjust the discounts for minority interest and lack of                               
                  marketability for these factors would be to duplicate                                
                  the reduction in reported value due to such factors.                                 
            On the basis of our reasoning in Estate of Berg, supra, Mr.                                
            Wilde's 5-percent increase in the net asset value discount                                 
            attributable to the general economic conditions of the Santa                               
            Barbara area is inappropriate.  Similarly, the 5-percent decrease                          
            in the net asset value discount attributable to Mr. Wilde's                                
            consideration of VIC's cash-flow and ability to pay dividends is                           
            inappropriate pursuant to the reasoning of Rev. Rul. 59-60, 1959                           
            C.B. 243, which is consistent with our conclusion in the instant                           
            case.  The estate additionally contends that Mr. Wilde's                                   
            adjustment for "Management Continuity" is already reflected in                             
            the value of MVN and MVS.  We do not agree.                                                

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