Estate of W. Clyde Wright - Page 7

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               (1) The economic outlook in general and the condition                   
                    and outlook of the specific industry;                              
               (2) The book value of the stock and financial                           
                    condition of the company;                                          
               (3) The earning capacity of the company;                                
               (4) The dividend-paying capacity;                                       
               (5) Whether or not the enterprise has goodwill or                       
                    other intangible value;                                            
               (6)  The market price of shares of stock of companies                   
                    engaged in the same or similar line of                             
                    business;                                                          
               (7) The company's net worth.                                            
               (8)  The size of the block of stock to be valued.                       

          See sec. 20.2031-2(f)(2), Estate Tax Regs.; Rev. Rul. 59-60,                 
          1959-1 C.B. 237.                                                             
               Petitioner’s first expert rated Wilber Bank, in comparison              
          to other U.S. banks with similar total assets, with respect to               
          return on assets, return on equity, asset quality (specifically              
          nonperforming loans), and liquidity, as indicated in the                     
          following schedule:                                                          

                                        Rating of Wilber Bank Among U.S.               
            Factors of Comparison       Banks With Similar Total Assets                
            Return on Assets                   Top           4%                        
            Return on Equity                   Top           21%                       
            Nonperforming Loans                Bottom        41%                       
            Liquidity                          Bottom        31%                       

               In October of 1990, an independent report published by First            
          Albany Corp. (First Albany report), a regional investment banking            




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