- 13 -
Commissioner, supra at 252; Silverman v. Commissioner, supra at
933.
Real estate valuation is a question of fact resolved on the
basis of the entire record. See Ahmanson Found. v. United States,
674 F.2d 761, 769 (9th Cir. 1981); Estate of Fawcett v.
Commissioner, 64 T.C. 889, 898 (1975). The trier of fact must
weigh all relevant evidence to draw the appropriate inferences.
See Commissioner v. Scottish Am. Inv. Co., 323 U.S. 119, 123-125
(1944); Helvering v. National Grocery Co., supra at 294-295;
Estate of Newhouse v. Commissioner, supra at 217. The standard
for valuation is fair market value, which is defined as the price
that a willing buyer would pay a willing seller, both persons
having reasonable knowledge of all relevant facts and neither
person being under a compulsion to buy or to sell. See sec.
20.2031- 1(b), Estate Tax Regs.; see also United States v.
Cartwright, 411 U.S. 546, 551 (1973); Estate of Simplot v.
Commissioner, 112 T.C. 130, 151 (1999). The standard is
objective, using a purely hypothetical willing buyer and seller
who are presumed to be dedicated to achieving maximum economic
advantage in any transaction involving the property, see Estate
of Simplot, supra at 152, which must be achieved in the context
of market and economic conditions at the valuation date, see
Estate of Newhouse v. Commissioner, supra at 218.
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