Estate of Charles a. Boratello, Deceased, C. Norman Borgatello and Josephine E. Donnelly, Co-Executors, and C. Norman Borgatello, Successor Trustee to the Charles A. Borgatello Living Trust - Page 23

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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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