Estate of Richie C. Heck, Deceased , Gary Heck, Special Administrator - Page 43

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          minority discount generally “reflects the minority shareholder’s            
          inability to compel liquidation and thereby realize a pro rata              
          share of the corporation’s net asset value”; i.e., the minority             
          shareholder’s share of total corporate net asset value.                     
               C.  Conclusion                                                         
               On the basis of the foregoing application of the DCF method,           
          taking into account certain discounts, we find that the fair                
          market value of the shares as of the valuation date was                     
          $20,269,736, or $32,174 a share.  See Appendix.                             
          VI.  Conclusion                                                             
               We shall redetermine a deficiency in Federal estate tax                
          commensurate with our finding that the value of the shares as of            
          the valuation date was $20,269,736.                                         

                                                  Decision will be entered            
                                             under Rule 155.                          

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