Estate of Alice Friedlander Kaufman - Page 18




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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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