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What would I do in this case? The only thing I can think of is to take the first available market price, which was on the 28th. For stocks that don't trade every day, you can interpolate or take an average. But in this case there is no prior trading history.

i'm not that familiar with tax accounting (so maybe somebody who is can weight in) but i have looked somewhat closely at GAAP rules governing the determination of "fair market value". presumably the tax rules are fairly similar in regards to these fundamental concepts.

despite the name, it is not the case that "fair market value" must only be determined by market prices; that's just considered the highest & best authority. sometimes these prices aren't available.

if you need to determine FMV an asset as of a certain date, and there are no readily quoted market prices available from independent 3rd parties, then you have to use other valuation methods, e.g. appraisal.

if you can find a comparable, you can infer valuation multiples (P/E, P/B, yield, etc.) & apply them to your case.

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