- 10 - Generally, only facts reasonably known on the valuation date provide a basis for the valuation. Estate of Newhouse v. Commissioner, supra at 218. In valuing closely held stock, discounts are often warranted to reflect the stock's lack of marketability and limitations on transferability. Estate of Newhouse v. Commissioner, supra at 249; Estate of Andrews v. Commissioner, supra at 953. The fair market value of closely held stock may be controlled for estate tax purposes by an enforceable agreement that fixes the price at which the stock can be sold during a taxpayer's lifetime and upon the decedent's death. Estate of Bischoff v. Commissioner, 69 T.C. 32, 39 (1977); Estate of Reynolds v. Commissioner, 55 T.C. 172, 188-189 (1970); Estate of Obering v. Commissioner, T.C. Memo. 1984-407; sec. 20.2031-2(h), Estate Tax Regs. Under the buy-sell and stock-purchase agreements involved in this case, if Brookshire failed to exercise its rights under the buy-sell agreements, neither decedent nor her estate was prohibited from selling the stock at a price lower or higher than the formula price. We conclude, and the parties do not dispute, that for Federal estate valuation purposes, the formula price set forth in the buy-sell and stock-purchase agreements does not control the value of the stock.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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