Estate of Richie C. Heck, Deceased , Gary Heck, Special Administrator - Page 13




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          buyer and seller are presumed to be dedicated to achieving the              
          maximum economic advantage, which advantage must be achieved in             
          the context of market conditions, the constraints of the economy,           
          and, assuming shares of stock are to be valued, the financial and           
          business experience of the subject corporation existing on the              
          valuation date.  Estate of Newhouse v. Commissioner, supra.                 
               In valuing shares of stock in a corporation whose shares are           
          not publicly traded, the factors we take into account include net           
          worth, prospective earning power and dividend paying capacity,              
          and other relevant factors, including the economic outlook for              
          the particular industry, the company’s position in the industry,            
          the company’s management, the degree of corporate control                   
          represented by the block of stock to be valued, and the value of            
          publicly traded stock or securities of corporations engaged in              
          the same or similar lines of business.  See sec. 2031(b);                   
          sec. 20.2031-2(f)(2), Estate Tax Regs.; Rev. Rul 59-60, 1959-1              
          C.B. 237, 238-242.                                                          
          III.  Expert Opinions                                                       
               A.  Introduction                                                       
               In this case, the parties rely heavily, if not exclusively,            
          on expert testimony to establish the fair market value of the               
          shares as of the valuation date.  Indeed, respondent’s only                 
          witness was Dr. Spiro.  In addition to Dr. Bajaj, petitioner                
          called Gary Heck, decedent’s son and Korbel’s president and                 






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