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decedent’s 287,620 WCB Holdings class A membership units and
4,621,166 WCB Holdings class B membership units.
The stipulation provides that the value of decedent’s WCB
Holdings class A membership units is equal to $32.24 less the
stipulated discounts for lack of control and lack of
marketability, multiplied by 287,620 (the total number of class A
governance and financial membership units decedent owned on the
alternate valuation date). As such, the value of decedent’s WCB
Holdings class A membership units was $6,655,527, as calculated
below.
[{$32.24 - ($32.24 x .13)} - {($32.24 - ($32.24 x .13)) x .175}]=
$23.14 x 287,620 = $6,655,527
We read the stipulation to further provide the WCB Holdings
class B membership units an additional 5-percent lack-of-voting-
rights discount. Given the stipulation and our holdings herein,
we find that the value of decedent’s WCB Holdings class B
membership units on the alternate valuation date was
$101,573,229,13 as calculated below.
[$23.14 - ($23.14 x .05)]= $21.98 x 4,621,166 = $101,573,229
13We note that decedent’s estate may be entitled to a
deduction under sec. 2056 for his inter vivos gift of WCB
Holdings class B membership units to Cynthia Bongard that was
pulled back into his gross estate under sec. 2035(a).
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