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nonvoting common stock Mr. Wall gave to his children, as of the
date of the gifts, was $2,570,000 or $273.99 per share.
Various Positions as to Value
The following table sets forth the various positions as to
value taken by the parties or their experts:
Event or Report Value per Share
Gift Tax Returns $221.75
Statutory Notices $260.13
Ms. Walker’s Original $211.20
Report
Ms. Walker’s Revised $211.20 (original report’s market-based
Report value)
$175.24 (new income-based value)
$192.20 (overall value conclusion)
Mr. Schroeder’s Report $303.03 (market-based value)
$260.61 (income-based value)
$273.99 (overall value conclusion)
Discussion
As we observed at the outset, the parties’ original
positions on the value of the gifts were quite close; this
litigation has driven the parties further apart. The overall
value asserted in Ms. Walker’s revised report is less than the
value asserted in her original report and the value claimed by
petitioners on their gift tax returns. Similarly, the value
asserted in Mr. Schroeder’s report is greater than the value
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