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having reasonable knowledge of relevant facts." Sec. 20.2031-
1(b), Estate Tax Regs. In the case of unlisted stock, the price
at which sales of stock are made in arm's-length transactions in
an open market is the best evidence of its value. Champion v.
Commissioner, 303 F.2d 887, 893 (5th Cir. 1962), revg. T.C. Memo.
1960-51; Estate of Andrews v. Commissioner, supra at 940. In the
instant case, the record does not disclose any such sales of the
stock interest in question. The record does disclose, however,
information with respect to the precedent transactions that
involved corporations in which decedent had an interest and
which, like B&W Longview, had portfolios of trade notes receiv-
able.
Where the value of unlisted stock cannot be determined from
actual sale prices, section 2031(b) provides that value is to be
determined by taking into consideration the value of stock of
corporations listed on an exchange that are engaged in the same
or similar business, as well as all other factors bearing on
value. The factors we must consider are those that an informed
buyer and seller would take into account. Hamm v. Commissioner,
supra at 938. Section 20.2031-2(f), Estate Tax Regs., lists some
of those factors, including the company's net worth, prospective
earning power, dividend-earning capacity, goodwill, the economic
outlook for its industry, its position in the industry, its
management, the degree of control represented by the block of
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