Estate of W. Clyde Wright - Page 6

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          reasonable knowledge of relevant facts.  United States v.                    
          Cartwright, 411 U.S. 546, 551 (1973); Collins v. Commissioner,               
          3 F.3d 625, 633 (2d Cir. 1993), affg. T.C. Memo. 1992-478; Estate            
          of Hall v. Commissioner, 92 T.C. 312, 335 (1989); sec.                       
          20.2031-1(b), Estate Tax Regs.  The question of fair market value            
          involves a question of fact, and the trier of fact must weigh all            
          relevant evidence and draw appropriate inferences.  Commissioner             
          v. Scottish Am. Inv. Co., 323 U.S. 119, 123-125 (1944); Hamm v.              
          Commissioner, 325 F.2d 934, 938 (8th Cir. 1963), affg. T.C. Memo.            
          1961-347; Estate of Newhouse v. Commissioner, 94 T.C. 193, 217               
          (1990); Estate of Andrews v. Commissioner, 79 T.C. 938, 940                  
          (1982).                                                                      
               In valuing shares of stock, the price at which shares are               
          sold, on a stock exchange, in an over-the-counter market, or                 
          otherwise, is often the best evidence of the value.  Dellacroce              
          v. Commissioner, 83 T.C. 269, 288 (1984); Estate of Damon v.                 
          Commissioner, 49 T.C. 108, 115 (1967); sec. 20.2031-2(b)(1),                 
          Estate Tax Regs.                                                             
               In addition to the selling price of shares of stock, other              
          factors and elements of value are often considered, particularly             
          where stock of a nonpublicly traded company is being valued.                 
          Estate of Gilford v. Commissioner, 88 T.C. 38, 49 (1987); sec.               
          20.2031-2(e), Estate Tax Regs.  Additional factors that are                  
          relevant in valuing shares of stock include the following:                   






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