Preface to the New Edition

Valuation issues permeate the Internal Revenue Code. Some people have estimated that there are several hundred sections in the Internal Revenue Code, as well as thousands of references in the Federal Tax Regulations, that deal with fair market valuation. Each year, taxpayers report on their tax returns millions of transactions that require estimates of value. Billions of tax dollars are at stake in valuations and, naturally, the Internal Revenue Service is interested in collecting the amount properly due the Government. Given the multitude of transactions and the significant amount of tax revenue at stake, there are frequent controversies over the issues related to correct valuation.

A book on the relationship between federal taxes and business valuation is therefore not only appropriate, but also timely. This book focuses on the law, procedure, and perspective of business valuation, exploring not just the rules, but also the policy or administrative reasons for implementing them. This is not a book on how to litigate before any particular court. There are many fine litigation treatises available, and one interested in learning more about federal litigation should consult them as the need occurs. In this book, the authors have drawn upon almost 75 years of combined practical experience in the areas of taxes and business valuation, to provide the reader with a comprehensive resource for education and practice.

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