-14-
other relevant factors bearing on value that would be considered
by an informed buyer and an informed seller. Polack v.
Commissioner, supra at 611; Estate of Fitts v. Commissioner,
supra at 731-732; Estate of Hall v. Commissioner, supra at 336.
In this regard, section 20.2031-2(f), Estate Tax Regs., states
that
If * * * actual sale prices and bona fide bid and asked
prices are lacking, then the fair market value is to be
determined by taking the following factors into
consideration:
* * * * * * *
(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
goodwill 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. In addition to
the relevant factors described above, consideration
shall also be given to nonoperating assets, including
proceeds of life insurance policies payable to or for
the benefit of the company, to the extent such
nonoperating assets have not been taken into account in
the determination of net worth, prospective earning
power and dividend-earning capacity. Complete
financial and other data upon which the valuation is
based should be submitted with the return, including
copies of reports of any examinations of the company
made by accountants, engineers, or any technical
experts as of or near the applicable valuation date.
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