- 16 - having reasonable knowledge of relevant facts." Sec. 20.2031- 1(b), Estate Tax Regs. In the case of unlisted stock, the price at which sales of stock are made in arm's-length transactions in an open market is the best evidence of its value. Champion v. Commissioner, 303 F.2d 887, 893 (5th Cir. 1962), revg. T.C. Memo. 1960-51; Estate of Andrews v. Commissioner, supra at 940. In the instant case, the record does not disclose any such sales of the stock interest in question. The record does disclose, however, information with respect to the precedent transactions that involved corporations in which decedent had an interest and which, like B&W Longview, had portfolios of trade notes receiv- able. Where the value of unlisted stock cannot be determined from actual sale prices, section 2031(b) provides that value is to be determined by taking into consideration the value of stock of corporations listed on an exchange that are engaged in the same or similar business, as well as all other factors bearing on value. The factors we must consider are those that an informed buyer and seller would take into account. Hamm v. Commissioner, supra at 938. Section 20.2031-2(f), Estate Tax Regs., lists some of those factors, including the company's net worth, prospective earning power, dividend-earning capacity, goodwill, the economic outlook for its industry, its position in the industry, its management, the degree of control represented by the block ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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