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buyer and seller are presumed to be dedicated to achieving the
maximum economic advantage, which advantage must be achieved in
the context of market conditions, the constraints of the economy,
and, assuming shares of stock are to be valued, the financial and
business experience of the subject corporation existing on the
valuation date. Estate of Newhouse v. Commissioner, supra.
In valuing shares of stock in a corporation whose shares are
not publicly traded, the factors we take into account include net
worth, prospective earning power and dividend paying capacity,
and other relevant factors, including the economic outlook for
the particular industry, the company’s position in the industry,
the company’s management, the degree of corporate control
represented by the block of stock to be valued, and the value of
publicly traded stock or securities of corporations engaged in
the same or similar lines of business. See sec. 2031(b);
sec. 20.2031-2(f)(2), Estate Tax Regs.; Rev. Rul 59-60, 1959-1
C.B. 237, 238-242.
III. Expert Opinions
A. Introduction
In this case, the parties rely heavily, if not exclusively,
on expert testimony to establish the fair market value of the
shares as of the valuation date. Indeed, respondent’s only
witness was Dr. Spiro. In addition to Dr. Bajaj, petitioner
called Gary Heck, decedent’s son and Korbel’s president and
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