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whether the estate met the “credible evidence” requirement
because, as a finder of facts, we consider essentially agreed
underlying facts and look to the experts’ reports for guidance in
order to resolve the valuation issue.
B. The Value of Godfrey on September 15, 1997
The parties have narrowed the focus of their controversy to
the question of the value of a 19.99-percent interest in Godfrey,
a closely held Deputy family corporation. For purposes of the
gift and estate tax provisions, the value of property transferred
on a particular date provides the base upon which the tax rate is
applied, after appropriate adjustments. See secs. 2001,
2501(a)(1). For purposes of the gift and estate tax property
value is determined by considering 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 to sell, and
both having reasonable knowledge of relevant facts. Sec.
20.2031-1(b) Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs.
The determination of the fair market value of property is a
factual determination, and the trier of fact must weigh all
relevant evidence of value and draw appropriate inferences.
Commissioner v. Scottish Am. Inv. Co., 323 U.S. 119, 123-125
(1944); Helvering v. Natl. Grocery Co., 304 U.S. 282, 294 (1938);
Symington v. Commissioner, 87 T.C. 892, 896 (1986).
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