- 17 - 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 valuePage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011