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Regs.; United States v. Cartwright, 411 U.S. 546, 551 (1973).
Fair market value reflects the price that 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.” United States
v. Cartwright, supra at 551; sec. 20.2031-1(b), Estate Tax Regs.
Fair market value is an objective test that relies on a
hypothetical buyer and seller. See Estate of Bright v. United
States, 658 F.2d 999, 1005-1006 (5th Cir. 1981); Rothgery v.
United States, 201 Ct. Cl. 183, 475 F.2d 591, 594 (1973); United
States v. Simmons, 346 F.2d 213, 217 (5th Cir. 1965); Estate of
Andrews v. Commissioner, 79 T.C. 938, 956 (1982). The willing
buyer and the willing seller are hypothetical persons, rather
than specific individuals or entities, and the individual
characteristics of these hypothetical persons are not necessarily
the same as the individual characteristics of the actual seller
or the actual buyer. Estate of Bright v. United States, supra at
1005-1006; Estate of Davis v. Commissioner, 110 T.C. 530 (1998)
(citing Estate of Curry v. United States, 706 F.2d 1424, 1428,
1431 (7th Cir. 1983)). The hypothetical willing buyer and
willing seller are presumed to be dedicated to achieving the
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