Estate of Helen M. Noble, Deceased, Leslie H. Noble, Jr., and John R. Noble, Co-Personal Representatives - Page 16

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                    (c) The book value of the stock and the financial                 
               condition of the business.                                             
                    (d) The earning capacity of the company.                          
                    (e) The dividend-paying capacity.                                 
                    (f) Whether or not the enterprise has goodwill or                 
               other intangible value.                                                
                    (g) Sales of the stock and the size of the block                  
               of the stock to be valued.                                             
                    (h) The market price of stocks of corporations                    
               engaged in the same or a similar line of business                      
               having their stocks actively traded in a free and open                 
               market, either on an exchange or over-the-counter.                     
               [Rev. Proc. 59-60, sec. 4.01.]                                         
          III.  Approaches to Valuation                                               
               In the case of nonpublicly traded stock the value of which             
          cannot be determined by relevant arm’s-length sales, fair market            
          value is generally determined by using three approaches.  The               
          first approach is the market approach.  The second approach is              
          the income approach.  The third approach is the asset-based                 
          approach.  Each of these three approaches includes various                  
          valuation methods.  The approach to apply in a given case is a              
          question of law.  Powers v. Commissioner, 312 U.S. 259, 260                 
          (1941); Bank One Corp. v. Commissioner, 120 T.C. at 306.                    
          Litigants in this Court are usually assisted by experts in                  
          applying these approaches.                                                  









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