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(c) The book value of the stock and the financial
condition of the business.
(d) The earning capacity of the company.
(e) The dividend-paying capacity.
(f) Whether or not the enterprise has goodwill or
other intangible value.
(g) Sales of the stock and the size of the block of
stock to be valued.
(h) The market price of stocks of corporations
engaged in the same or a similar line of business
having their stocks actively traded in a free and open
market, either on an exchange or over-the-counter.
In short, the fair market value of the Demco stock is a
question of fact that depends on all the circumstances. See
Anderson v. Commissioner, 250 F.2d 242, 249 (5th Cir. 1957),
affg. in part and remanding in part on another ground T.C. Memo.
1956-178; Estate of Newhouse v. Commissioner, supra at 217;
Skripak v. Commissioner, 84 T.C. 285, 320 (1985). The weight to
be accorded any particular evidentiary factor is also to be
determined by the circumstances. See sec. 25.2512-2(f), Gift Tax
Regs.
As is customary in valuation cases, the parties primarily
rely on expert opinion evidence to support their positions.
We evaluate expert opinions in light of the demonstrated
qualifications of each expert and all other evidence in the
record. See Anderson v. Commissioner, supra at 249; Parker v.
Commissioner, supra at 561. We have broad discretion to evaluate
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