Estate of Paul Mitchell, Deceased, Patrick T. Fujieki, Executor - Page 34

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          (1993);  Messing v. Commissioner, 48 T.C. 502, 512 (1967); sec.             
          20.2031-1(b), Estate Tax Regs.  Fair market value may be affected           
          by future events that were reasonably foreseeable at the valuation          
          date. Estate of Gilford v. Commissioner, 88 T.C. 38, 52 (1987);             
          Gray v. Commissioner, 2 B.T.A. 672, 682 (1925); Estate of Livermore         
          v. Commissioner, T.C. Memo. 1988-503.                                       
               Determining  the  fair  market  value  of  a  closely  held            
          corporation's capital stock is difficult because it involves                
          property that has no public market.  The best method for valuing            
          closely held stock is by reference to an actual arm's-length sale           
          of the stock in the normal course of business within a reasonable           
          time before or after the valuation date.  See Estate of Andrews v.          
          Commissioner, 79 T.C. 938, 940 (1982); Estate of Campbell v.                
          Commissioner, T.C. Memo. 1991-615; sec. 20.2031-2(b), Estate Tax            
          Regs.  In the absence of an arm's-length sale, the fair market              
          value of closely held stock must be determined indirectly by                
          considering, inter alia:                                                    
               (a) The nature of the business and the history of the                  
               enterprise from its inception.                                         
               (b) The economic outlook in general and the condition and              
               outlook of the specific industry in particular.                        
               (c) The book value of the stock and the financial                      
               condition of the business.                                             
               (d) The earning capacity of the company.                               
               (e) The dividend paying capacity [of the company].                     






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