Estate of Cyril I. Magnin, Deceased, Donald Isaac Magnin, Executor - Page 29




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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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