Banc of America downgrades Sirius Satellite Radio (SIRI

) to sell from neutral.

Analyst Jonathan Jacoby believes the current valuation more than discounts near-term catalysts that might be envisioned. He says the stock could move higher with better than expected subscription numbers by a Stern move, a Toyota deal, and/or speculation on take-out.

However, based on his valuation metrics, at yesterday's closing price, the stock is discounting 14.5 million subscribers by 2010, significantly ahead of even his super-bullish scenario of 12 million. Jacoby has a new $3.6 billion target price, based on discounted cash flow, Price/Forward free cash flow, and perpetuity value of net present value/subscriptions.