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(f) Whether or not the enterprise has goodwill or other
intangible value.
(g) * * * the size of the block of stock to be valued.
(h) The market price of stocks of corporations engaged
in the same line or similar line of business having their
stocks actively traded in a free and open market, either
on an exchange or over-the-counter.
Rev. Rul. 59-60, sec. 4.01, 1959-1 C.B. 237, 238-239; see also sec.
20.2031-2(f), Estate Tax Regs. These factors cannot be applied
with mathematical precision. See Rev. Rul. 59-60, supra, 1959-1
C.B. at 238. Rather, the weight accorded each factor must be
tailored to account for the particular facts under consideration.
See Messing v. Commissioner, supra.
Both parties relied upon expert valuations. At times, expert
testimony aids the Court in determining valuation; in other
instances, it does not. See Laureys v. Commissioner, 92 T.C. 101,
129 (1989). We are not bound by an expert's formulae and opinions,
especially when they run contrary to our judgment. Chiu v.
Commissioner, 84 T.C. 722, 734 (1985). Instead, we may reach a
decision as to the value of the property based on our own analysis
of all the evidence in the record, Hamm v. Commissioner, supra at
941, using all of one party's expert opinion, Buffalo Tool & Die
Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980), or
selectively using any portion of such an opinion, see Parker v.
Commissioner, 86 T.C. 547, 562 (1986).
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