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corporation’s stock is to rely on actual arm’s-length sales of
the stock within a reasonable period of the valuation date. See
Estate of Andrews v. Commissioner, 79 T.C. 938, 940 (1982).
There were no such sales of Dunn Equipment stock. In the absence
of such sales, fair market value is determined from the value of
stock in corporations engaged in the same or similar business as
well as other factors relevant to value. See sec. 2031(b).
Under section 20.2031-2(f), Estate Tax Regs., these other factors
include the company’s net worth, its prospective earning power
and dividend-paying capacity, its goodwill, its position in the
industry, its management, the economic outlook in the industry,
the degree of control represented by the block of stock to be
valued, and the values of stock of corporations engaged in the
same or similar lines of business listed on a stock exchange.
Because the record is devoid of any evidence regarding the value
of stock in companies engaged in the same or a similar business,
we determine fair market value by considering other factors
relevant to value.
Both parties rely on expert opinion. Expert opinion
sometimes aids the Court in determining valuation; other times,
it does not. See Laureys v. Commissioner, 92 T.C. 101, 129
(1989). We evaluate such opinions in light of the demonstrated
qualifications of the expert and all other evidence of value in
the record. See Estate of Newhouse v. Commissioner, 94 T.C. 193,
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