- 6 -
Estate Tax Regs.; see also United States v. Cartwright, 411 U.S.
546, 551 (1973); Estate of Hall v. Commissioner, 92 T.C. 312,
335 (1989). The willing buyer and the willing seller are
hypothetical persons, instead of specific individuals or
entities, and the characteristics of these hypothetical persons
are not necessarily the same as the personal characteristics of
the actual seller or a particular buyer. Estate of Bright v.
United States, 658 F.2d 999, 1005-1006 (5th Cir. 1981);
Estate of Newhouse v. Commissioner, 94 T.C. 193, 218 (1990).
Special rules govern the valuation of corporate stock,
depending on whether the stock is listed on an established
securities market. When stock is so listed, its value usually
equals its listed market price. When stock is not listed on an
established market, its value is usually based on the
arm's-length sales (if any) of the unlisted stock that have
occurred within a reasonable time of the valuation date.
Estate of Andrews v. Commissioner, 79 T.C. 938, 940 (1982);
Duncan Indus., Inc. v. Commissioner, 73 T.C. 266, 276 (1979).
In the absence of recent arm's-length sales, the value of
unlisted stock should be determined by taking into account the
value of listed stock of corporations engaged in the same or a
similar line of business. Sec. 2031(b); Estate of Hall v.
Commissioner, supra at 336. Unlisted stock must also be valued
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011