- 6 - of death. See sec. 2031(a); sec. 20.2031-1(b), Estate Tax Regs. Fair market value is defined as the price at which property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts. See United States v. Cartwright, 411 U.S. 546, 551 (1973); Estate of Brookshire v. Commissioner, T.C. Memo. 1998-365; sec. 20.2031-1(b), Estate Tax Regs. Fair market value involves a question of fact, and facts reasonably known on the valuation date are particularly relevant. See Estate of Newhouse v. Commissioner, 94 T.C. 193, 217-218 (1990); Estate of Brookshire v. Commissioner, supra. Arm's- length sales of stock within a reasonable time before and after the appropriate valuation date are strong indicators of fair market value. See Estate of Andrews v. Commissioner, 79 T.C. 938, 940 (1982); Estate of Brookshire v. Commissioner, supra. Additional factors that are relevant in valuing shares of stock in closely held corporations are: The financial condition of the corporation, the value of listed stock of corporations engaged in similar lines of business, the corporation's net worth, the size of the block of stock to be valued, and the earning and dividend paying capacity of the corporation. See Estate of Newhouse v. Commissioner, supra at 217-218; Estate of Hall v. Commissioner, 92 T.C. 312, 336 (1989); Estate of WrightPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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