George Tanner died October 2, 2023, survived by his son Thomas and his daughter Gigi Tanner Stewart and her children, Sam and Cindy. George was the sole stockholder of Tanner, Inc., a C corporation. Gigi served as president of Tanner from its inception until early January 2022. However, she never had an employment agreement or a noncompete agreement with Tanner, Inc. George was not involved with the business; he simply provided the funding. Gigi executed all of Tanner’s contracts with its customers and was very involved with the business. George’s will left half of the Tanner stock to Gigi and the other half to Thomas. In late December 2021, Gigi and Thomas had major disagreements, and soon thereafter Gigi formed a C corporation (GTS, Inc.) to compete with Tanner, Inc. Because of the personal relationships Gigi had with Tanner’s customers, almost all of them broke their contracts with Tanner and began doing business with GTS. Preparation of George’s estate tax return is underway, and one of the estate’s major assets is the Tanner stock. A question has arisen whether the valuation of the Tanner stock should take into account the value of Gigi’s personal goodwill, given the absence of an employment agreement or a noncompete agreement. If so, the value of her personal goodwill would adversely affect the value otherwise determined for the stock. Your supervisor requested that you research this issue and present your results in a memo so she can discuss the valuation issue with the person who is preparing an appraisal of the Tanner stock.