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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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