Historically, Virginia courts have used numerous and inconsistent methods to value business interests. Such terms as value, fair value, fair market value and the like have been used. The Court of Appeals, in Bosserman v. Bosserman, 9 Va. App. 1, 384 S.E.2d 104 (1989) which involved an ownership interest in a real estate holding company, set forth a definitive standard of value – intrinsic worth – stating, “Trial courts valuing marital property for the purpose of making a monetary award must determine from the evidence that value which represents the property’s intrinsic worth to the parties upon dissolution of the marriage.” In Bosserman, the Court of Appeals, in approving the business valuation of the spouse’s expert, affirmed the trial court’s rejection of the value of the stock set forth in corporate bylaws. In Howell v. Howell, the trial court was confronted with a similar situation. George Howell was a partner at Hunton & Williams. The partnership agreement defined the value of the partnership interest upon termination or death. At termination or death, the agreement entitled the partner to receive only the balance of his capital account and his share of the net income. When the trial court found that Mr. Howell’s business or organization goodwill at Hunton & Williams was valuable and constituted marital property, Mr. Howell appealed, contending that his Wife was thereby receiving more than he, himself, was entitled to under the partnership agreement. The Court of Appeals affirmed the trial court. It cited Bosserman and reaffirmed that intrinsic value is the standard of value in divorce cases. Howell defined intrinsic value: “Intrinsic value is a very subjective concept that looks to the worth of the property to the parties. The methods of valuation must take into account the parties themselves and the different situations in which they exist. The item may have no established market value, and neither party may contemplate selling the item; indeed, sale may be restricted or forbidden. Commonly, one party will continue to enjoy the benefits of the property while the other must relinquish all future benefits. Still, its intrinsic value must be translated into a monetary amount. The parties must rely on accepted methods of valuation, but the particular method of valuing and the precise application of that method to the singular facts of the case must vary with the myriad situations that exist among married couples.” In Howell, the Court noted that shareholder or partnership agreements should be considered by the Court (and impliedly by the valuators), but not treated as conclusive. In general, then, intrinsic value is the going-concern value in the hands of the owner.