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numerous shares of stock would bring if each share was sold on the
same day. Estate of Van Horne v. Commissioner, 78 T.C. 728, 742
(1982), affd. 720 F.2d 1114 (9th Cir. 1983); see also Helvering v.
Safe Deposit & Trust Co., 95 F.2d at 812. The test is the amount
that a hypothetical seller could realize if skilled brokers disposed
of all shares in a reasonable period of time in accordance with
prudent practices of liquidation. See Richardson v. Commissioner,
supra at 103; Mott v. Commissioner, 139 F.2d 317 (6th Cir. 1943),
affg. a Memorandum Opinion of this Court; Helvering v. Maytag,
125 F.2d at 63; Bull v. Smith, 119 F.2d 490, 492 (2d Cir. 1941);
Estate of Van Horne v. Commissioner, supra at 742; Frank v.
Commissioner, 54 T.C. 75, 100 (1970), affd. 447 F.2d 552 (7th Cir.
1971); Estate of Prell v. Commissioner, 48 T.C. 67, 72 (1967). We
believe that the same test applies in ascertaining the presence of a
market absorption discount. If hypothetical brokers could have sold
all essentially similar assets within a reasonable period of time
after the valuation date, at the per-piece market rate, then no
discount for market absorption is appropriate. The assets could be
absorbed by the market quickly, making the quoted market price the
most representative indicium of the assets' value on the valuation
date. Rushton v. Commissioner, 498 F.2d 88, 92 n.10 (5th Cir. 1974),
affg. 60 T.C. 272 (1973); Bankers Trust Co. v. United States, 207 Ct.
Cl. 422, 518 F.2d 1210, 1222 (1975).
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