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APPENDIX B
Calculation of Value of Decedent’s 50 Shares C&L Bailey Stock
Estate Tax
Return Petitioner Respondent Holding
Value of C&L Bailey’s $2,965,662 $1,945,651 $2,861,903 $2,861,903
adjusted net assets
25% ownership percentage $741,416 $486,413 $715,476 $715,476
Combined valuation discount
rate (percent) 50 160 41.952 50
Amount of discount $370,708 $291,848 $300,157 $357,738
Discounted value of 50 shares $370,708 $194,565 $415,319 $357,738
1 As indicated in note 10 of the opinion, on brief petitioner erroneously
treats the 40-percent claimed minority discount and 20-percent agreed-upon
minority discount as being additive rather than multiplicative.
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