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business represented by the block of stock to be valued, and the
values of securities of corporations engaged in the same or
similar lines of business that are listed on a stock exchange.
See sec. 20.2031-2(f)(2), Estate Tax Regs. Section 4 of Rev.
Rul. 59-60, 1959-1 C.B. 237, 238-242, sets forth criteria that
are virtually identical to those listed in section 20.2031-
2(f)(2), Estate Tax Regs., and "has been widely accepted as
setting forth the appropriate criteria to consider in determining
fair market value". Estate of Newhouse v. Commissioner, supra at
217. Section 5 of Rev. Rul. 59-60, 1959-1 C.B. 242-243, which
addresses the weight to be given the relevant factors depending
on the nature of the company's business, provides in pertinent
part:
(a) Earnings may be the most important criterion
of value in some cases whereas asset value will receive
primary consideration in others. In general, the
appraiser will accord primary consideration to earnings
when valuing stocks of companies which sell products or
services to the public; conversely, in the investment
or holding type of company, the appraiser may accord
the greatest weight to the assets underlying the se-
curity to be valued.
Regardless whether the corporation whose stock is being
valued is seen primarily as an operating company or primarily as
an investment company, the Courts should not restrict consider-
ation to only one approach to valuation, such as capitalization
of earnings or net asset value. See Hamm v. Commissioner, 325
F.2d 934, 941 (8th Cir. 1963), affg. T.C. Memo. 1961-347; Estate
of Andrews v. Commissioner, 79 T.C. 938, 945 (1982). The degree
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