- 18 - valued, and the amount and type of its nonoperating assets if not considered elsewhere. See Estate of Hall v. Commissioner, supra at 336; Estate of Andrews v. Commissioner, 79 T.C. at 940; Estate of Cloutier v. Commissioner, T.C. Memo. 1996-49; sec. 20.2031- 2(f), Estate Tax Regs.; Mandelbaum v. Commissioner, supra. Second, we must determine by how much, if any, our estimated publicly traded value should be discounted to reflect the fact that the stock is unlisted and not easily marketable. See Mandelbaum v. Commissioner, supra; see also Estate of Cloutier v. Commissioner, supra (marketability discount generally represents the additional price that an unlisted share would command if it were freely traded). Factors to consider to determine the applicability and amount of a marketability discount include: (1) The value of the subject corporation's privately traded securities vis-a-vis its publicly traded securities (or, if the subject corporation does not have stock that is traded both publicly and privately, the cost of a similar corporation's public and private stock); (2) an analysis of the subject corporation's financial statements; (3) the corporation's dividend-paying capacity, its history of paying dividends, and the amount of its prior dividends; (4) the nature of the corporation, its history, its position in the industry, and its economic outlook; (5) the corporation's management; (6) the degree of control transferred with the block of stock to be valued; (7) any restriction on the transferability of the corporation's stock; (8) the period of time for which an investorPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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