- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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