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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, taxpayers
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