- 29 - 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.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011