In determining the value of any business or interest therein, a fair appraisal as of the date of the transferor's death should be made of all assets of the business, both tangible and intangible, including goodwill, and the business or interest therein should be given a net value equal to the amount which a willing purchaser, whether an individual or a corporation, would pay therefor in view of the new value of the assets of the business and its demonstrated earning capacity.

All factors relative to the valuation of other property, if applicable, will be considered in determining the valuation of a proprietary or partnership interest in a business. All evidence bearing upon such valuation should be submitted to the State Controller or the inheritance tax referee, including copies of reports in any case in which examinations of the business have been made by accountants, engineers, or other technical experts as of or near the date of the transferor's death.

Note: Reference: Section 13951, Revenue and Taxation Code.