- 10 - As of the beginning of the second quarter of 1994, the U.S. economy had a largely positive outlook. It had enjoyed 12 straight quarters of economic growth and was experiencing some of the lowest interest and inflation rates in more than two decades. As of the alternate valuation date, market growth for the uniform industry was anticipated; the career apparel sector of the uniform industry was growing rapidly, as companies learned the benefits of easily identifiable employees and advertising created by the professional image. Seminole budgeted approximately $1.5 million to be spent in its 1994 fiscal year on expansion and a new computer system. OPINION We must determine the fair market value of the estate's Seminole stock on the applicable valuation date. Fair market value is a factual determination, and the trier of fact must weigh all relevant evidence of value and draw appropriate inferences. See Commissioner v. Scottish Am. Inv. Co., 323 U.S. 119, 123-125 (1944); Helvering v. National Grocery Co., 304 U.S. 282, 294 (1938); Symington v. Commissioner, 87 T.C. 892, 896 (1986); Zmuda v. Commissioner, 79 T.C. 714, 726 (1982), affd. 731 F.2d 1417 (9th Cir. 1984). Fair market value is measured on the applicable valuation date, which, in this case, is 6 months after the day decedent died. See sec. 2032(a); Estate of Proios v. Commissioner, T.C. Memo. 1994-442; see also Pabst Brewing Co. v. Commissioner, T.C. Memo. 1996-506. When the Commissioner determines fair market value, as is the case at hand, taxpayersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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