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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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