In Arnaud v. Stockgrowers State Bank, 268 Kan. 163, 992 P.2d 216 (Kan 1999), the majority shareholders of a closely held bank initiated a reverse stock split, leaving the minority with a fractional share, which was later eliminated. The Kansas dissenters' rights statutes required the payment of "fair value" for those eliminated shares. See KanStatAnn 17-6405 (1995). In determining the fair value, the bank applied a 23% minority discount. The Kansas Supreme Court determined that it was inappropriate to apply a minority discount to the dissenters' shares. The court stated that: "To allow a discount under the facts of this case would discourage investments in corporations by persons who would acquire a minority interest because it would enable the majority shareholders to seize the minority shareholders' interest in the corporation to the extent a minority . . . discount is allowed. Investments should be encouraged, not discouraged." (Arnaud, 992 P.2d at 220.) That court would not permit such a windfall to the majority shareholder. Id.