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stock to be valued, and nonoperating assets to the extent not
otherwise considered. Section 5 of Rev. Rul. 59-60, 1959-1 C.B.
237, 238-242, sets forth criteria that are virtually identical to
those listed in section 20.2031-2(f), Estate Tax Regs., and "has
been widely accepted as setting forth the appropriate criteria to
consider in determining fair market value". Estate of Newhouse
v. Commissioner, 94 T.C. 193, 217 (1990).
There is no fixed formula for applying the foregoing fac-
tors. See Estate of Goodall v. Commissioner, 391 F.2d 775, 786
(8th Cir. 1968), vacating T.C. Memo. 1965-154. We have held, and
the regulations provide, that the weight to be given to the
various factors in arriving at fair market value depends upon the
facts of each case. Estate of Andrews v. Commissioner, supra at
940-941; sec. 20.2031-2(f), Estate Tax Regs. As the trier of
fact, we have broad discretion in assigning the weight to accord
to the various factors and in selecting the method of valuation.
Estate of O'Connell v. Commissioner, 640 F.2d 249, 251 (9th Cir.
1981), affg. on this issue T.C. Memo. 1978-191.
Each of the parties' experts agree that, under the transac-
tion method that each applied under the market approach to
valuation, the starting point for determining the fair market
value of the stock interest in question should be the book value
of B&W Longview on the valuation date plus a 23-percent premium
on the gross amount of the trade notes receivable that that
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