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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 investor
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