- 6 - point and revg. in part on another ground T.C. Memo. 1986-318. The fair market value of a property interest is determined under the “willing buyer-willing seller standard” set forth in section 20.2031-1(b), Estate Tax Regs., as follows: The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts. The fair market value of a particular item of property includible in the decedent’s gross estate is not to be determined by a forced sale price. Nor is the fair market value of an item of property to be determined by the sale price of the item in a market other than that in which such item is most commonly sold to the public, taking into account the location of the item wherever appropriate * * *. It is implicit that the buyer and seller have knowledge of all the relevant facts concerning the valuation property. United States v. Cartwright, 411 U.S. 546, 551 (1973). It is also implicit that the buyer and seller would aim to maximize profit and/or minimize cost in the setting of a hypothetical sale. See Estate of Watts v. Commissioner, 823 F.2d 483, 486 (11th Cir. 1987), affg. T.C. Memo. 1985-595; Estate of Newhouse v. Commissioner, 94 T.C. 193, 218 (1990). Therefore, we consider the view of both the hypothetical buyer and seller. Kolom v. Commissioner, 644 F.2d 1282, 1288 (9th Cir. 1981), affg. 71 T.C. 235 (1978). The estates offered three expert witnesses, and respondent offered one. The estates’ experts were found to be qualified, and their reports were received as their direct testimony inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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