- 8 -
Cartwright, 411 U.S. 546, 551 (1973); Estate of Andrews
v. Commissioner, 79 T.C. 938, 940 (1982). This is an
objective test based upon hypothetical buyers and sellers
in the marketplace and is not based upon a particular buyer
or seller. See Estate of Bright v. United States, 658 F.2d
999, 1005-1006 (5th Cir. 1981); Estate of Andrews v.
Commissioner, supra at 956.
The value of an item of property as of the date of a
person's death is a question of fact. See Hamm v. Commis-
sioner, 325 F.2d 934, 938 (8th Cir. 1963), affg. T.C. Memo.
1961-347; Estate of Newhouse v. Commissioner, 94 T.C. 193,
217 (1990). The taxpayer bears the burden of proving that
respondent's determination of fair market value of property
is incorrect. See Rule 142(a). The Court as the trier of
fact must weight all relevant evidence and draw appropriate
inferences. See, e.g., Estate of Hall v. Commissioner, 92
T.C. 312, 335 (1989).
The determination of fair market value is an
inherently imprecise process. See Estate of Gilford v.
Commissioner, 88 T.C. 38, 50 (1987); Buffalo Tool & Die
Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980).
On numerous occasions, this Court has stressed the
appropriateness of settling valuation issues. See Estate
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