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little or no value unless they are significant. Mr. Stewart
added the 50-percent life-income interest, $28,500, to the voting
rights interest in the other 50 percent of Joseph’s stock,
$2,000, to determine an overall value of approximately $30,500.
vi. Value of Remainder Transferred by Cyril
Respondent assigns a total value of $244,000 to Cyril’s
entire stock interests, of which $123,000 is allocated to the
remainder interest transferred by Cyril. The following chart
summarizes how respondent determined the value of Cyril’s entire
stock interest:
Entity No. of Shares Per Share Value Total Value
JM:
Common 75,044 $2.41 $180,856
Preferred 11,035 1.33 14,677
Common option 18,158 1.41 25,603
Specialty:
Common 47.5 152.00 7,220
Preferred 25,000 .625 15,625
Total 243,981
Mr. Stewart applied a remainder factor of .50413 to the $244,000
figure he determined to be the value of Cyril’s entire stock
interests in JM and Specialty as of October 31, 1951, yielding a
remainder interest amount of $123,000. Thus, Mr. Stewart
determined that the value of the property interest transferred by
Cyril as of October 31, 1951, was $123,000.
2. The Estate’s Expert
The estate relied on the report and testimony of its expert
appraiser, Mr. Browning. The parties agree that Mr. Browning
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