Barry Means and his spouse Mary want to transfer their one- third (1/ 3) stock interest in The Diamond Ridge Golf Course to a trust for the benefit of their two children. The couple’s CPA has advised that such a “gift” is a taxable event, the tax consequence of which can only be determined by valuing the company and their one- third (1/ 3) stock interest therein. You have been engaged to value the Meanses’ stock interest for the purpose of filing a gift tax return. Assume that the date of the gift is December 31, 2012. Since this valuation is for tax purposes, the factors outlined in Rev. Rul. 59– 60 apply. Identify these factors and discuss each within the context of this engagement scenario, using the factual information for The Diamond Ridge Golf Course provided in the chapter.
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