Liquid Air Corporation and Subsidiaries - Page 9

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          willing seller, neither being under any compulsion to buy or to             
          sell and both having reasonable knowledge of relevant facts."               
          Sec. 20.2031-1(b), Estate Tax Regs.; see also Bankers Trust Co.             
          v. United States, 207 Ct. Cl. 422, 437, 518 F.2d 1210, 1219                 
          (1975).  Where the property to be valued consists of corporate              
          stock that is listed on an established securities market, the               
          average exchange price quoted on the valuation date generally               
          provides the most accurate measure of fair market value.  Bankers           
          Trust Co. v. United States, 207 Ct. Cl. at 437, 518 F.2d at 1219;           
          Amerada Hess Corp. v. Commissioner, 517 F.2d 75, 83 (3d Cir.                
          1975), revg. White Farm Equip. Co. v. Commissioner, 61 T.C. 189             
          (1973); sec. 20.2031-2(b)(1), Estate Tax Regs.  However, where              
          stock is exchanged for property pursuant to an arm's-length                 
          transaction, the courts have, in certain instances, presumed that           
          the value of such stock equals the value of the property received           
          in exchange therefor, a method often referred to as the "barter-            
          equation method" of valuation.  Southern Natural Gas Co. v.                 
          United States, 188 Ct. Cl. 302, 352-353, 412 F.2d 1222, 1252                
          (1969); Pittsburgh Terminal Corp. v. Commissioner, supra at 88;             
          Moore-McCormack Lines, Inc. v. Commissioner, 44 T.C. 745, 757               
          (1965).  Regardless of the precise rule of valuation that we are            
          attempting to apply, this Court has always followed the evidence            
          of value on either side of a transaction that we consider to be             
          the most reliable.  Pittsburgh Terminal Corp. v. Commissioner,              
          supra at 88; Amerex Holding Corp. v. Commissioner, 37 B.T.A.                




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