- 6 - 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 purposesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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