Estate of Thomas A. Fleming, Deceased, Cathy J. Hirt, Independent Successor Executrix - Page 17

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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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