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(d) The earning capacity of the company.
(e) The dividend-paying capacity.
(f) Whether or not the enterprise has goodwill or
other intangible value.
(g) Sales of the stock and the size of the block of
stock to be valued.
(h) The market price of stocks of corporations
engaged in the same or a similar line of business
having their stocks actively traded in a free and open
market, either on an exchange or over-the-counter.
[Rev. Rul. 59-60, 1959-1 C.B. at 238-239.]
Because valuation may not be reduced to the rote application of
formulas, and because of the imprecision inherent in determining
fair market value of stock that lacks a public market (and the
Solomon-like pronouncements that often follow), we again remind
the parties that these matters are better resolved by agreement
rather than trial by ordeal in which conflicting opinions of the
experts are pitted against each other. See Estate of Hall v.
Commissioner, supra; Messing v. Commissioner, 48 T.C. 502, 512
(1967); see also Buffalo Tool & Die Manufacturing Co. v.
Commissioner, 74 T.C. 441 (1980).
As is customary in valuation cases, the parties rely
primarily on expert opinion evidence to support their contrary
valuation positions. We evaluate the opinions of experts in
light of the demonstrated qualifications of each expert and all
other evidence in the record. Anderson v. Commissioner, supra;
Parker v. Commissioner, 86 T.C. 547, 561 (1986). We have broad
discretion to evaluate "`the overall cogency of each expert's
analysis.’" Sammons v. Commissioner, 838 F.2d 330, 334 (9th Cir.
1988) (quoting Ebben v. Commissioner, 783 F.2d 906, 909 (9th Cir.
1986), affg. in part and revg. in part T.C. Memo. 1983-200),
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