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 30




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            to be $3,378,914.  In order to arrive at the discount                                      
            attributable to the future tax, Mr. Wilde divided $3,378,914 (the                          
            present value of the future tax) by $18,223,290 (the total value                           
            of VIC's real estate and investments) to arrive at a 19-percent                            
            (rounded from 18.5 percent) discount.  Accordingly, Mr. Wilde's                            
            discount is not calculated as a percentage of net asset value;                             
            rather, it is calculated as a percentage of the value of VIC's                             
            real estate and investment property.  Mr. Wilde errs in                                    
            calculating the discount attributable to the tax on the built-in                           
            gain this manner.                                                                          
                  Mr. Wilde errs in that the present value of the future tax                           
            should have been stated as a percentage of net asset value, not                            
            as a percentage of only VIC's real estate and investments.  The                            
            estate correctly points out that the figure that Mr. Wilde                                 
            arrives at "is irrelevant for purposes of calculating the                                  
            percentage amount by which the taxes reduce the net asset value,                           
            because it excludes some assets and all liabilities."  As a                                
            percentage of net asset value, the discount amount would not be                            
            19 percent.  The present value of the future tax, $3,378,914,                              
            divided by Mr. Wilde's net asset value, $16,443,000 produces a                             
            20.5-percent discount.  Accordingly, after correcting that error,                          
            the discount attributable to the tax on the built-in gains                                 







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