Estate of George C. Blount, Deceased, Fred B. Aftergut, Executor - Page 70

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          shares that are the subject of the redemption obligation are                
          being valued.  To do so would be to value BCC in its                        
          postredemption configuration; namely, after decedent’s shares had           
          been redeemed and BCC’s assets had been contracted by the $4                
          million redemption payment.  Valuing decedent’s 43,080 shares by            
          means of the hypothetical willing buyer/seller construct                    
          necessarily requires that the corporation’s actual obligation to            
          redeem the shares be ignored; such a stance is inherent in the              
          fiction that the shares are being sold to a hypothetical third-             
          party buyer on the valuation date rather than being redeemed by             
          the corporation.  To the hypothetical willing buyer, decedent’s             
          43,080 BCC shares constituted an 83.2-percent interest in all of            
          the assets and income-generating potential of BCC on the                    
          valuation date, including any assets that might be used to                  
          satisfy the actual redemption obligation.  To treat the                     
          corporation’s obligation to redeem the very shares that are being           
          valued as a liability that reduces the value of the corporate               
          entity thus distorts the nature of the ownership interest                   
          represented by those shares.                                                
               By contrast, a hypothetical willing buyer of BCC shares                
          other than decedent’s would treat the redemption obligation, on             
          the valuation date, as a corporate liability of BCC, but only in            
          connection with a simultaneous accounting of the impact of the              

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