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Cartwright, 411 U.S. 546, 551 (1973); sec. 25.2512-1, Gift Tax
Regs. The fair market value of donated property as of a given
date is a question of fact to be determined from the entire
record. Symington v. Commissioner, 87 T.C. 892, 896 (1986).
In determining the value of unlisted stock, actual arm’s-
length sales of such stock in the normal course of business
within a reasonable time before or after the valuation date are
the best criteria of market value. Duncan Indus., Inc. v.
Commissioner, 73 T.C. 266, 276 (1979). In the absence of arm’s-
length sales, the value of the stock is to be determined by
taking into consideration the company’s net worth, prospective
earning power, dividend-paying capacity, and other relevant
factors. Estate of Andrews v. Commissioner, 79 T.C. 938, 940
(1982); sec. 25.2512-2(f), Gift Tax Regs. Such other relevant
factors include the goodwill of the business, the economic
outlook in the particular industry, the company’s position in the
industry and its management, the degree of the control of the
business represented by the block of stock to be valued, and the
values of securities of corporations engaged in the same or
similar lines of business that are listed on a stock exchange.
The weight to be accorded such comparisons or any other
evidentiary factors considered in the determination of a value
depends upon the facts of each case. Sec. 25.2512-2(f), Gift Tax
Regs. These factors cannot be applied with mathematical
precision. Estate of Andrews v. Commissioner, supra at 941.
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