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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. 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. Helvering v. Natl. Grocery Co., 304 U.S.
282, 294 (1938); Symington v. Commissioner, 87 T.C. 892, 896
(1986); sec. 20.2031-1(b), Estate Tax Regs.
The determination of the fair market value of a closely held
(unlisted) stock may be effectively established by reference to
arm’s-length sales of the same stock within a reasonable time
before or after the valuation date. See, e.g., Ward v.
Commissioner, 87 T.C. 78, 101 (1986). Absent an arm’s-length
sale, fair market value is normally determined using the
hypothetical willing buyer and seller model. Estate of Hall v.
Commissioner, 92 T.C. 312, 335-336 (1989). Implicit in that
model is the axiom that the seller would attempt to maximize
profit and the buyer to minimize cost. Estate of Curry v. United
States, 706 F.2d 1424, 1429 (7th Cir. 1983); Estate of Newhouse
v. Commissioner, 94 T.C. 193 (1990).
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