Estate of George C. Blount, Deceased, Fred B. Aftergut, Executor - Page 81

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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                       
               To reflect the foregoing and the concessions of the parties,           

                                                  Decision will be entered            
                                             under Rule 155.                          

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