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gains tax because that is what a hypothetical willing seller and a
hypothetical willing buyer would have done under the facts and
circumstances existing on that date. Petitioner adopts the view
of petitioner's expert Mr. Howard and argues that the full amount
of such tax should reduce ADDI&C's net asset value in making that
determination. On the record before us, we reject petitioner's
position and Mr. Howard’s opinion. On that record, we find that,
where no liquidation of ADDI&C or sale of its assets was planned
or contemplated on the valuation date, the full amount of ADDI&C's
built-in capital gains tax may not be taken as a discount or
adjustment in determining the fair market value on that date of
each of the two blocks of stock in question, even though we have
found that as of that date it was unlikely that ADDI&C could have
avoided all of ADDI&C’s built-in capital gains tax, and the record
does not show that there was any other way as of that date by
which ADDI&C could have avoided all of such tax. See Ward v.
Commissioner, 87 T.C. 78 (1986); Estate of Andrews v.
Commissioner, 79 T.C. 938 (1982); Estate of Piper v. Commissioner,
72 T.C. 1062 (1979).
We thus are in agreement with petitioner's expert Mr. Pratt
and respondent's expert Mr. Thomson that in the present case it is
not appropriate in valuing each of the two blocks of ADDI&C stock
in question to apply a discount or adjustment equal to the full
amount of ADDI&C's built-in capital gains tax. Nonetheless, on
the instant record, we find that on the valuation date there was
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