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amount, if any, of the excess of the value of the shares of
common stock that decedents surrendered in the Recapitalization
of August 24, 1981, over the value of the shares of preferred
stock that they received in the exchange. The amount of any such
excess, by augmenting the value of Robert's common stock in FIC,
would be a taxable gift from decedents to Robert. See Estate of
Trenchard v. Commissioner, T.C. Memo. 1995-121 supplemented by
T.C. Memo. 1995-232; sec. 25.2511-1(h)(1), Gift Tax Regs.
Valuation is a question of fact, and the trier of fact must
weigh all relevant evidence to draw the appropriate inferences.
Commissioner v. Scottish Am. Inv. Co., 323 U.S. 119, 123-125
(1944); Helvering v. National Grocery Co., 304 U.S. 282, 294-295
(1938); Anderson v. Commissioner, 250 F.2d 242, 249 (5th Cir.
1957), affg. in part and remanding in part T.C. Memo. 1956-178;
Estate of Newhouse v. Commissioner, 94 T.C. 193, 217 (1990);
Skripak v. Commissioner, 84 T.C. 285, 320 (1985).
Fair market value is defined for Federal estate and gift tax
purposes as the price that a willing buyer would pay a willing
seller, both having reasonable knowledge of all the relevant
facts and neither being under compulsion to buy or to sell.
United States v. Cartwright, 411 U.S. 546, 551 (1973) (citing
sec. 20.2031-1(b), Estate Tax Regs.); see also Snyder v.
Commissioner, 93 T.C. 529, 539 (1989); Estate of Hall v.
Commissioner, 92 T.C. 312, 335 (1989). The willing buyer and the
willing seller are hypothetical persons, rather than specific
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