Nathan P. and Geraldine V. Morton - Page 6

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             Jung v. Commissioner, supra.  In considering such events,                
             appropriate adjustments must be made for changes in                      
             inflation, general economic conditions in the industry,                  
             technological advances, and similar factors.  Id.  For                   
             example, a subsequent arm's-length sale of the property                  
             appropriately adjusted to take account of general economic               
             differences between the valuation date and the date of the               
             sale is relevant because it provides evidence of the value               
             of the property on the valuation date.  See id. at 431-432.              
             Indeed, this and other courts have recognized on many                    
             occasions that:                                                          

                  In determining the value of unlisted stocks,                        
                  actual sales made in reasonable amounts at arm's                    
                  length, in the normal course of business within                     
                  a reasonable time before or after the valuation                     
                  date are the best criteria of market value.                         
                  [Duncan Indus. v. Commissioner, 73 T.C. 266, 276                    
                  (1979) (citing Fitts' Estate v. Commissioner, 237                   
                  F.2d 729 (8th Cir. 1956), affg. T.C. Memo. 1955-                    
                  269.  See also Estate of Jung v. Commissioner,                      
                  supra; Estate of Andrews v. Commissioner, 79                        
                  T.C. 938, 940 (1982); Estate of Campbell v.                         
                  Commissioner, T.C. Memo. 1991-615.]                                 

                  In light of the foregoing, we find that each of the                 
             items at issue except for the CompUSA prospectus is                      
             relevant to our determination of the value of SWI stock as               
             of June 30, 1989.  The Dubin Clark memorandum describing                 
             the terms of its purchase of SWI (item number 1 above) and               
             the memorandum prepared by Continental Bank for purposes                 

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