Doris F. Rabenhorst and Alvin P. Rabenhorst, Sr. - Page 6

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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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