Nathan P. and Geraldine V. Morton - Page 24

                                       - 24 -                                         
             Estate Tax Regs.  In the absence of such sales, fair                     
             market value is determined 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                            
                  (f) Whether or not the enterprise has                               
                       goodwill or other intangible value;                            
                  (g) The size of the block of stock to be                            
                       valued; and                                                    
                  (h) The market price of stock 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. at                          
                       237, 238-239; see also sec. 20.2031-                           
                       2(f), Estate Tax Regs.]                                        

             These factors are not intended to be all-inclusive, and                  
             cannot be applied with mathematical certainty.  See Rev.                 
             Rul. 59-60 sec. 3.01, 1959-1 C.B. at 238.  Because                       
             petitioners made a section 83(b) election with respect                   
             to the subject stock, and because the restrictions on the                
             stock were not perpetual, the value of the SWI stock for                 

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