Below is a estate tax situation. Have I stated the facts right in the form of a question? Is the issue sound reasonable? Authorities section: I am struggling to find the main IRC reference as well as any cases that back this estate tax problem.

Tax Situation:

John dies suddenly at his home. John owns stock in a closely held corporation. Margie is the executor of the estate. She comes to Famous Tax Service Inc. looking for advice on valuing the stock.

Facts: Form of question.

How to perform a proper valuation of John's stock from his closely held corporation as it relates to his valuation of his estate?

Issue:

John had stock from his closely held corporation at the time of his death and needing a valuation of the stock to properly value his estate. Difficulty of determining FMV due to the possibility that John owned all of the stock and there may be little, if any, trading of the shares have taken place.

Authorities: Primary Authority (Statutory Authority - Internal Revenue Code; Admin Authority-Regulations, Rev Rulings; Judicial Authorities-Cases

-Section 2031(b)

-Rev. Rul. 54-76, C.B. 1954-1, 194

-Rev. Rul. 157 C.B. 1953-2, 255, and Rev. Rul. 189, C.B. 1953-2, 294

-Sections 2031(a), 2032 and 2512(a)

Thanks.