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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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