Estate of Arthur G. Scanlan, Deceased, Ruth B. Scanlan, Administratrix - Page 13

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          312, 335 (1989).  The willing buyer and the willing seller are                     
          hypothetical persons, instead of specific individuals or                           
          entities, and the characteristics of these imaginary 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, supra at 218.                                            
                Special rules govern the valuation of corporate stock.  When                 
          stock is listed on an established securities market, the stock's                   
          value usually equals its listed market price.  When stock is not                   
          listed on an established securities market, the stock’s value is                   
          usually based on arm's-length sales (if any) that have occurred                    
          within a reasonable time of the valuation date.  In the absence                    
          of any such arm’s-length sales, the value of unlisted stock is                     
          based on the value of listed stock of the subject corporation,                     
          or, if the corporation has no listed stock, the listed stock of                    
          like corporations engaged in the same or a similar line of                         
          business.9  Unlisted stock must also be valued by reference to                     
          the subject corporation's net worth, its prospective earning                       
          power, its dividend-earning capacity, its goodwill, its                            
          management, its position in the industry, the economic outlook                     
          for its industry, the degree of control represented by the block                   


                9 Like corporations are determined by reference to the                       
          subject corporation's age, business (e.g., manufacturer,                           
          retailer), product line, and gross receipts.                                       




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