Estate of Helen M. Noble, Deceased, Leslie H. Noble, Jr., and John R. Noble, Co-Personal Representatives - Page 15

                                        -15-                                          
               The Commissioner has also set forth in a longstanding                  
          ruling, Rev. Rul. 59-60, 1959-1 C.B. 237, certain criteria to               
          consider in determining fair market value.  That ruling, which is           
          widely accepted in the valuation community and which is regularly           
          referenced by the judiciary and the Commissioner alike, Polack v.           
          Commissioner, supra at 611, states that the                                 
               Valuation of securities is, in essence, a prophesy as                  
               to the future and must be based on facts available at                  
               the required date of appraisal.  As a generalization,                  
               the prices of stocks which are traded in volume in a                   
               free and active market by informed persons best reflect                
               the consensus of the investing public as to what the                   
               future holds for the corporations and industries                       
               represented.  When a stock is closely held, is traded                  
               infrequently, or is traded in an erratic market, some                  
               other measure of value must be used.  In many                          
               instances, the next best measure may be found in the                   
               prices at which the stocks of companies engaged in the                 
               same or a similar line of business are selling in a                    
               free and open market.  [Rev. Proc. 59-60, sec. 3.03,                   
               1959-1 C.B. at 238.]                                                   
          The ruling then states that in the absence of relevant market               
          quotations, all available financial data and all relevant factors           
          affecting fair market value must be considered in valuing the               
          stock of a closely held corporation.  Id. sec. 4.01.  The ruling            
          lists as relevant eight specific factors.  These factors, which             
          are virtually identical to the factors referenced in section                
          20.2031-2(f), Estate Tax Regs., are:                                        
                    (a) The nature of the business and the history of                 
               the enterprise from its inception.                                     
                    (b) The economic outlook in general and the                       
               condition and outlook of the specific industry in                      
               particular.                                                            





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