Chapter 19

Valuations for Federal Tax Matters

There is more definitive precedential case law in the general area of valuations for federal tax purposes than for any other business valuation purpose. Some issues are well settled, but decisions on other issues continue to evolve. This chapter attempts to distinguish which issues are well settled, nearly settled, or still in flux.1

Even among tax issues that are well settled in principle, there is still room for argument about magnitudes, especially in such areas as discounts for minority interest and lack of marketability. There are also issues about which decisions seem to be conflicting (for example, discounts for lack of marketability for controlling interests). However, as Judge David Laro ...

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