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closely held corporation. While listed market prices are the
benchmark in the case of publicly traded stock, recent arm’s-
length transactions generally are the best evidence of fair
market value in the case of unlisted stock. Estate of Andrews v.
Commissioner, 79 T.C. 938, 940 (1982); Duncan Indus., Inc. v.
Commissioner, 73 T.C. 266, 276 (1979). Where the value of
unlisted stock cannot be determined from actual sale prices,
value is determined by taking into consideration the value of
listed stock in comparable corporations engaged in the same or a
similar line of business, as well as all other factors bearing on
value, including analysis of fundamentals. Sec. 2031(b); Estate
of Newhouse v. Commissioner, supra at 217; Estate of Hall v.
Commissioner, supra at 336. The factors that we must consider
are those that an informed buyer and an informed seller would
take into account. Hamm v. Commissioner, 325 F.2d 934, 940 (8th
Cir. 1963), affg. T.C. Memo. 1961-347. Rev. Rul. 59-60, 1959-1
C.B. 237, "has been widely accepted as setting forth the
appropriate criteria to consider in determining fair market
value", Estate of Newhouse v. Commissioner, supra at 217; it
lists the following factors to be considered, which are virtually
identical to those listed in section 20.2031-2(f), Estate Tax
Regs.:
(a) The nature of the business and the history of the
enterprise from its inception.
(b) The economic outlook in general and the condition
and outlook of the specific industry in particular.
(c) The book value of the stock and the financial
condition of the business.
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