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(2) In the case of shares of stock, the
company’s net worth, prospective earning power and
dividend-paying capacity, and other relevant factors.
Some of the “other relevant factors” * * * are: the
good will of the business; the economic outlook in the
particular industry; the company’s position in the
industry and its management; the degree of control of
the business represented by the block of stock to be
valued; and the values of securities of corporations
engaged in the same or similar lines of business which
are listed on a stock exchange. However, the weight to
be accorded such comparisons or any other evidentiary
factors considered in the determination of a value
depends upon the facts of each case. * * *
Rev. Rul. 59-60, 1959-1 C.B. 237, 238-239, lists eight
factors that are particularly relevant to the fair market value
of stock of closely held companies as follows:
(1) The nature of the business and the history of the
enterprise;
(2) The general economic outlook and the particular
outlook for the specific industry;
(3) The financial condition of the business and its
book value;
(4) The earning capacity of the company;
(5) The dividend-paying capacity of the company;
(6) The value of any intangible assets and goodwill;
(7) Previous sales of the stock and the size of the
interest to be valued; and
(8) The market price of stocks of corporations engaged in
the same or a similar line of business having their
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