Estate of Wayne-Chi Young, Deceased, Tsai-Hsiu Hsu Yang, Executrix - Page 17

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          situated."  It provides that the time of valuation is at the date           
          of decedent's death (or the alternate valuation date as provided            
          by section 2032).                                                           
               Value is "the price at which the property would change hands           
          between a willing buyer and a willing seller, neither being under           
          any compulsion to buy or to sell and both having reasonable                 
          knowledge of relevant facts."  United States v. Cartwright, 411             
          U.S. 546, 551 (1973); Estate of Hall v. Commissioner, 92 T.C.               
          312, 335 (1989); Estate of Heckscher v. Commissioner, 63 T.C.               
          485, 490 (1975); sec. 20.2031-1(b), Estate Tax Regs.  The willing           
          seller and the willing buyer are hypothetical rather than                   
          specific individuals or entities.  Estate of Bright v. United               
          States, 658 F.2d 999, 1005-1006 (5th Cir. 1981).  The                       
          determination of value is to be made as of the valuation date,              
          and knowledge of unforeseeable future events that may have                  
          affected the value cannot be attributed to the hypothetical buyer           
          or seller.  Sec. 20.2031-1(b), Estate Tax Regs.                             
               Real estate valuation is a question of fact to be resolved             
          on the basis of the entire record.  Ahmanson Found. v. United               
          States, 674 F.2d 761, 769 (9th Cir. 1981); Estate of Fawcett v.             
          Commissioner, 64 T.C. 889, 898 (1975).  After determining the               
          gross value of the property, there may be adjustments upward or             
          downward for such factors affecting value as minority discounts,            
          discounts for lack of marketability, control premiums, and                  





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