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See, e.g., Estate of Davis v. Commissioner, supra; Estate of
Piper v. Commissioner, 72 T.C. 1062, 1069-1070 (1979). The net
asset value method involves arriving at the company's net asset
value (the value of the company's assets less liabilites, where
the assets have been adjusted to reflect their fair market value)
and then discounting that value to account for various factors
that affect its marketability. Principal factors affecting the
discount in the instant case are the tax liability inherent in
the built-in gain assets of VIC and the lack of marketability due
to the difficulty of selling stock in a small closely held
corporation such as VIC. We do not employ a fixed formula in
considering the factors that we use to determine the fair market
value of unlisted stock. See Estate of Davis, 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.
25.2512-2(f), Gift Tax Regs. We have broad discretion in
assigning weight 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; sec. 25.2512-2(f), Gift Tax
Regs. The determination of the value of closely held stock is a
matter of judgment rather than one of mathematics. See Estate of
Davis, supra at 537. Moreover, because the valuation is
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