- 26 - should not consider factors that have already been taken into account in the valuation of VIC's assets. We agree with the estate. As pertains to cash-flow and dividend paying capacity, Section 5 of Rev. Rul. 59-60, 1959-1 C.B. 243, provides in pertinent part: (b) The value of the stock of a closely held investment or real estate holding company, whether or not family owned, is closely related to the value of the assets underlying the stock. For companies of this type, the appraiser should determine the fair market values of the assets of the company. Operating expenses of such a company and the cost of liquidating it, if any, merit consideration when appraising the relative values of the stock and the underlying assets. The market values of the underlying assets give due weight to potential earnings and dividends of the particular items of property underlying the stock, capitalized at rates deemed proper by the investing public at the date of appraisal. A current appraisal by the investing public should be superior to the retrospective opinion of an individual. For these reasons, adjusted net worth should be accorded greater weight in valuing the stock of a closely held investment or real estate holding company, whether of not family owned, than any of the customary yardsticks of appraisal, such as earnings and dividend paying capacity. [Emphasis added.] The revenue ruling implies that potential earnings are already accounted for in the market value of MVN and MVS and should not be considered again in valuing the VIC stock. As pertains to economic conditions and the softness in the real estate market, in Estate of Berg v. Commissioner, T.C. Memo. 1991-279, affd. inPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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