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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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