Assume D died owning 40 million shares of General Motors stock. Would you use the same method of valuing that stock in his estate as you would use for valuing 100 shares? Would the problem differ if D were a recognized sculptor, and who died owning as many of his sculptures as those owned by others? See Estate of Smith v. Commissioner, 57 T.C. 650 (1972), aff'd 510 F.2d 479 (2d. Cir. 1975).