Estate of James Waldo Hendrickson - Page 34




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          these hypothetical persons are not necessarily the same as the               
          individual characteristics of an actual seller or an actual                  
          buyer.  See Estate of Curry v. United States, 706 F.2d 1424,                 
          1428-1429, 1431 (7th Cir. 1983); Estate of Bright v. United                  
          States, 658 F.2d 999, 1005-1006 (5th Cir. 1981); Estate of                   
          Newhouse v. Commissioner, supra at 218; see also Estate of Watts             
          v. Commissioner, 823 F.2d 483, 486 (11th Cir. 1987), affg. T.C.              
          Memo. 1985-595.  The hypothetical willing buyer and willing                  
          seller are presumed to be dedicated to achieving the maximum                 
          economic advantage.  See Estate of Curry v. United States, supra             
          at 1428; Estate of Newhouse v. Commissioner, supra at 218.  This             
          advantage must be achieved in the context of market and economic             
          conditions at the valuation date.  See Estate of Newhouse v.                 
          Commissioner, supra at 218.                                                  
               For Federal estate tax purposes, the fair market value of               
          the subject property is generally determined as of the date of               
          death of the decedent; ordinarily, no consideration is given to              
          any unforeseeable future event that may have affected the value              
          of the subject property on some later date.  See sec. 20.2031-               
          1(b), Estate Tax Regs.; see also First Natl. Bank v. United                  
          States, 763 F.2d 891, 893-894 (7th Cir. 1985); Estate of Newhouse            
          v. Commissioner, supra at 218; Estate of Gilford v. Commissioner,            
          88 T.C. 38, 52 (1987).                                                       
               Special rules apply to the valuation of the stock of a                  
          closely held corporation.  While listed market prices are the                




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