Burgess J.W. Raby & William L. Raby have published Reflecting Tax on Built-In Gain When Valuing Stock, also available on the Tax Analysts web site as Doc 2005-12523, 2005 TNT 110-54:

Since the Second Circuit reversed the Tax Court on the question of valuation reductions for built-in gain tax liability in valuing stocks in Eisenberg v. Commissioner, 155 F.3d 50 (2d Cir. 1998), and the IRS acquiesced in AOD CC-1999-001, business appraisers, the Tax Court, and tax practitioners generally have struggled toward an understanding of how to apply the Eisenberg holding.  When and how should a valuation reflect the differences a hypothetical buyer would perceive between an equity interest in an entity whose assets have a fair market value approximating its tax basis and one whose FMV meaningfully exceeds its tax basis?  The latest opinion on that point, Estate of Frazier Jelke III v. Commissioner, T.C. Memo. 2005-131, suggests there are aspects of built-in gain tax that have yet to be resolved.