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Accordingly, for the foregoing reasons we conclude that the
$3,146,134 in life insurance proceeds should be added to the
$6,750,000 value previously determined, with the result that BCC
had a fair market value of $9,896,134 on the valuation date.
III. Conclusion
Both experts derived the value of decedent’s 43,080 shares
by multiplying their final blended values for BCC by decedent’s
83.2-percent ownership interest. Neither applied any discounts
or premiums. We are persuaded that this approach is appropriate
here. Multiplying BCC’s total value of $9,896,134 by 83.2
percent yields a value for decedent’s 43,080 shares of $8,233,583
on the valuation date.
Because we are persuaded by a preponderance of the evidence
that the fair market value of decedent’s BCC stock exceeded the
amount respondent determined, we sustain respondent’s
determination.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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