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There was, for the tax years at issue, no explicit authorization in the cost sharing regulations for the Commissioner’s “akin” to a sale theory or his inclusion of workforce in place, goodwill, or going-concern value in determining the buy-in payment for pre-existing intangibles. The “aggregation” proposed by the Commissioner did not yield a reasonable means, much less the most reliable means, of determining an arm’s-length buy-in payment where the Commissioner’s principal valuation expert’s business-enterprise approach improperly aggregated pre-existing intangibles (which were subject to the buy-in payment) and subsequently developed intangibles (which were not). The comparable uncontrolled transaction method provided the best method for determining the fair market value of all three species of intangible property. Decision was entered in favor of the Petitioner. The court ruled that the Commissioner’s primary valuation approach was arbitrary and capricious.