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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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