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(1973). The standard to be applied here is objective, utilizing
a hypothetical willing buyer and seller. The foregoing analysis
is not, however, a specific standard that focuses on any
particular buyer or seller. See Propstra v. United States, 680
F.2d 1248, 1251-1252 (9th Cir. 1982). In addition, the
determination of the fair market value of property is a matter of
sound judgment, rather than of mathematics. See In re Estate of
Williams, 256 F.2d 217, 220 (9th Cir. 1958), affg. T.C. Memo.
1956-239. Moreover, since valuation is necessarily an
approximation, it is not required that the value we determine be
one as to which there is specific evidence, provided it is within
the range of figures that properly can be deduced from the
record. Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir.
1976), affg. T.C. Memo. 1974-285; Hamm v. Commissioner, 325 F.2d
934, 939-940 (8th Cir. 1963), affg. T.C. Memo. 1961-347. Fair
market value is determined on the applicable valuation date,
which, in this case, is the date that Old Lorvic's assets were
acquired by petitioner, and the agreements were implemented.
Pabst Brewing Co. v. Commissioner, T.C. Memo. 1996-506.
Respondent suggests petitioner possesses an incentive to
allocate a large amount to the covenant not to compete because
petitioner could amortize that amount over the life of the
covenant. In that vein, respondent asserts that the payments
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