§ 20.2031-3 - Valuation of interests in businesses.

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The fair market value of any interest of a decedent in a business, whether a partnership or a proprietorship, is the net amount which a willing purchaser whether an individual or a corporation, would pay for the interest to a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts. The net value is determined on the basis of all relevant factors including—

A fair appraisal as of the applicable valuation date of all the assets of the business, tangible and intangible, including good will;

The demonstrated earning capacity of the business; and

The other factors set forth in paragraphs (f) and (h) of § 20.2031-2 relating to the valuation of corporate stock, to the extent applicable.