Other methods.

(iii) Other methods. Intangible assets described in 1.897-1(f)(1)(ii) may be valued pursuant to any other reasonable method at an amount reflecting the price at which the asset would change hands between an unrelated willing buyer and willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of all relevant facts. However, a corporation that uses a method of valuation other than the purchase price or book value methods may be required to comply with the special notification requirements of 1.897-2(h)(1)(iii)(A).


26 CFR § 1.897-1

Scoping language

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