Fair Market Value

(1) In determining the value of economic benefits, the value of property, including the

right to use property, is its fair market value. See Treas. Reg. 53.4958-4(b)(1)(i).

(2) Treas. Reg. 53.4958-4(b)(1)(i) defines fair market value as:

a. The price at which property, or the right to use property, would change hands

between a willing buyer and a willing seller,

b. Neither being under any compulsion to buy, sell or transfer property or the

right to use property, and

c. Both having reasonable knowledge of relevant facts.