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date. Estate of Andrews v. Commissioner, 79 T.C. 938, 940
(1982). In the absence of arm's-length sales, the value of
unlisted stock may be based on the value of listed stock of the
subject corporation, or, if the corporation has no listed stock,
the listed stock of like corporations engaged in the same or a
similar line of business. Sec. 2031(b); Estate of Hall v.
Commissioner, 92 T.C. 312, 336 (1989). Unlisted stock may also
be valued indirectly by reference to the subject corporation's
net worth, its prospective earning power, its dividend-earning
capacity, its goodwill, its management, its position in the
industry, the economic outlook for its industry, the degree of
control represented by the block of its stock to be valued, and
the amount and type of its nonoperating assets if not considered
elsewhere. See Estate of Hall v. Commissioner, supra at 335;
Estate of Andrews v. Commissioner, supra at 940; sec. 20.2031-
2(f), Estate Tax Regs.; see generally Rev. Rul. 59-60, 1959-1
C.B. 237. In ascertaining the value of stock in a decedent's
estate, all shares of that stock are aggregated. See Ahmanson
Found. v. United States, 674 F.2d 761 (9th Cir. 1981).
When ascertaining the value of unlisted stock by reference
to listed stock, a discount from the listed price may be
warranted in order to reflect the unlisted stock's lack of
marketability. Such a discount, commonly known as a
"marketability discount", reflects the absence of a recognized
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