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aggregate value of the Specialty common stock to be $152,000, or
$152 per share.
iv. Valuation of JM Stock Options
Mr. Stewart determined that the value of the JM common stock
held by Joseph and subject to an option by Cyril should be
allocated between Joseph and Cyril. Mr. Stewart allocated the $1
option price to Joseph. Mr. Stewart then subtracted the $1
option price from the value he placed on the JM common stock,
$2.41, and allocated $1.41 per share to Cyril for the JM common
stock subject to the option. With respect to the Nichols
options, Mr. Stewart did not determine that any portion of the
value of the stock should be apportioned to Cyril. Respondent
has not assigned a value to the Nichols options, nor has
respondent argued that the Nichols options must be considered in
determining the value of the interest transferred by Cyril.23
v. Value of Consideration Received by Cyril
On brief, respondent argues that the amount of the
consideration received by Cyril was limited to approximately
$30,500,24 based on the report and testimony of Mr. Stewart.
23Any value assigned to these options would result in a
larger interest being transferred by Cyril per the 1951 Agreement
and would enlarge any disparity between the remainder interest he
transferred and the consideration he received from Joseph.
24In the amended answer, respondent argued that Cyril
received no consideration, within the meaning of sec. 2036, for
the interest he transferred to his children.
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