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Number of
Preferred
Date Shares Redeemed
Sept. 3, 1999 5
Mar. 9, 2000 42
Sept. 14, 2000 11
Dec. 6, 2000 142
Total 200
After petitioner’s redemption of the above 200 shares, 2,110
of the 3,188.55 preferred shares that the father had owned
remained outstanding. Mr. Wechsler and Gilbert (as co-
fiduciaries of both their father’s and mother’s estates)
determined that the two estates had satisfied the Federal estate
taxes they owed. Mr. Wechsler and Gilbert further determined
they were each entitled to 1,055 of the remaining 2,110 preferred
shares that their father had owned in petitioner. On December 7,
2000, petitioner redeemed Gilbert’s 1,055 preferred shares for
$2,299,099.25, or $2,179.24 a share. Mr. Wechsler’s 1,055
preferred shares were not formally transferred to him or
redeemed. As of the time of the trial, the certificates
representing these 1,055 preferred shares that Mr. Wechsler
inherited remained in the name of the father’s estate, the
mother’s estate, or the trusts.
From June 1, 1991, through August 7, 1997, petitioner’s then
180 outstanding shares of common stock were owned as follows:
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