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market value of Schlegel UK, and that respondent's experts failed
to analyze the facts and use the appropriate standard in
determining the value of Schlegel UK. With respect to Schlegel
GmbH, petitioner argues that the value of Schlegel GmbH stock on
November 30, 1989, was $2.6 million because the company had no
goodwill, few assets of value, and no prospect of growing its
earnings in the period after the valuation date and that the
basis of Schlegel Corporation in Schlegel GmbH was $4,750,220.
Valuation is a question of fact, and the trier of fact must
weigh all relevant evidence on the date of valuation, without
regard to hindsight, to draw the appropriate inferences. See
Estate of Jung v. Commissioner, 101 T.C. 412, 423-424 (1993);
Estate of Newhouse v. Commissioner, 94 T.C. 193, 217 (1990);
Estate of Andrews v. Commissioner, 79 T.C. 938, 940 (1982).
Future events foreseeable on the valuation date may be considered
in deciding fair market value. See Estate of Newhouse v.
Commissioner, supra at 218.
For Federal tax purposes, fair market value is the price
that a willing buyer would pay a willing seller, both having
reasonable knowledge of all of the relevant facts and neither
being under compulsion to buy or to sell. See United States v.
Cartwright, 411 U.S. 546, 551 (1973); 1.170A-1(c)(2), Income Tax
Regs. The willing buyer and the willing seller are hypothetical
persons, rather than specific individuals or entities, and the
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