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          companies.  Mr. Herber has not persuaded us that these factors              
          support a lower minority interest discount.                                 
                    c.  Our Analysis                                                  
               We are unsatisfied that either expert has adequately                   
          supported his recommended minority interest discount.   The                 
          estate does not argue for a minority interest discount greater              
          than 17 percent.  Mr. Herber, who started with a minority                   
          interest discount range of 18.4 to 19.6 percent before making               
          various adjustments that we do not find well supported, has not             
          persuaded us that the minority interest discount should be less             
          than 17 percent.  Accordingly, we hold that a 17-percent minority           
          interest discount is appropriate in valuing decedent’s shares of            
          RBI stock.                                                                  
               2.  Lack of Marketability Discount                                     
               Mr. Schroeder determined a lack of marketability discount of           
          40 percent, and Mr. Herber determined a lack of marketability               
          discount of 25 percent.  Both experts used information from                 
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