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to which a corporation is actively engaged in producing income
rather than merely holding property for investment should influ-
ence the weight to be given to the values arrived at under
different valuation approaches. However, it should not dictate
the use of one approach to the exclusion of all others. See
Estate of Andrews v. Commissioner, supra.
There is no fixed formula for applying the factors that are
to be considered in determining the fair market value of unlisted
stock. See Hamm v. Commissioner, supra at 938; Estate of Davis
v. Commissioner, supra at 536. The weight to be given to the
various factors in arriving at fair market value depends upon the
facts of each case. See sec. 20.2031-2(f), Estate Tax Regs. As
the trier of fact, we have broad discretion in assigning the
weight to accord to the various factors and in selecting the
method of valuation. See Estate of O'Connell v. Commissioner,
640 F.2d 249, 251-252 (9th Cir. 1981), affg. on this issue and
revg. in part T.C. Memo. 1978-191; Estate of Davis v. Commis-
sioner, supra at 537; see also sec. 20.2031-2(f), Estate Tax
Regs.
The determination of the value of closely held stock, like
the stock of Marrero Land in which decedent held an interest on
the valuation date, is a matter of judgment, rather than of
mathematics. See Hamm v. Commissioner, supra at 940; Estate of
Davis v. Commissioner, supra. Moreover, since valuation is
necessarily an approximation, it is not required that the value
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