- 18 - 938, 940 (1982); sec. 20.2031-2(f), Estate Tax Regs. These factors cannot be applied with mathematical precision; thus, the weight to be given to each factor must be tailored to account for the specific facts of the case at hand. See Messing v. Commissioner, 48 T.C. 502, 512 (1967). Additionally, the rights, restrictions, and limitations of the various classes of stock must be considered in making valuation determinations. See Estate of Newhouse v. Commissioner, 94 T.C. 193, 218 (1990); Estate of Anderson v. Commissioner, T.C. Memo. 1988-511. The factors to be considered are those that an informed buyer and an informed seller would take into account. See Hamm v. Commissioner, 325 F.2d 934, 940 (8th Cir. 1963), affg. T.C. Memo. 1961-347. Rev. Rul. 59-60, 1959-1 C.B. 237, has been widely accepted as setting forth the appropriate criteria to consider in determining the fair market value of stock of closely held corporations. See Estate of Newhouse v. Commissioner, supra at 217. The following factors, which are virtually identical to those listed in section 20.2031-2(f), Estate Tax Regs., are to be considered: (a) The nature of the business and the history of the enterprise from its inception. (b) The economic outlook in general and the condition and outlook of the specific industry in particular. (c) The book value of the stock and the financialPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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