Estate of Lynn M. Rodgers, deceased, First National Bank of Commerce, Executor - Page 17




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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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