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discount was wanted before E&Y completed the reports. Mr.
Francis did not receive draft reports in advance.
Transactions Between Shareholders
From 1994 to 2000, there have been approximately 90
transactions of Huber shares between shareholders. The
shareholders are not obligated to use the E&Y value to sell their
shares. The relationships between buyers and sellers varied.
Some were as close as between parents and children or
grandparents and grandchildren. Others were as distant as
between a trust and a spouse of a second cousin. Other
transactions involved nonprofit organizations which sold shares
to Huber family members. Each of these sales occurred at the E&Y
value.
Petitioners timely filed their Forms 709 for the taxable
years 1997 to 2000 reflecting gifts of Huber shares from
petitioners to their lineal descendants. Petitioners based the
values assigned to the shares on the valuation reports prepared
by E&Y. At trial, petitioners relied principally on two sets of
transactions as representative examples of the 90 sales: The
Brown estate transactions (Brown estate) and the Anne Foster
trust transactions (Foster trust).
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