Cal. Code Regs. tit. 18 § 15551
The value of any property for the purpose of taxation under the Gift Tax Law is ordinarily the market value of the property at the date of the gift. "Market value," as a general rule, is the price that a willing buyer would pay to a willing seller of property, neither being under any compulsion to buy or sell.
If there is more than one unit of property included in a gift, the market value of the whole will generally be determined by ascertaining the market value on the date of the gift of each individual unit. In the case of a gift of stocks or bonds, each stock or bond will be treated as an individual unit.
All relevant facts and elements of value as of the time of a gift will be considered in determining its value.
NOTE: Reference: Section 15551, Revenue and Taxation Code.
Cal. Code Regs. Tit. 18, § 15551