Business Valuation Store | Just Published! BVRs Business Valuation Sourcebook, 2010 Edition

Just Published! BVRs Business Valuation Sourcebook, 2010 Edition


		Price: $99.00 (US Dollars)
		Just Published! Your time is valuable. Don’t waste it hunting for hard-to-find documents!BVR’s Business Valuation Sourcebook is the essential, go-to reference for the appraisal profession. This Sourcebook compiles first generation content, including IRS code, regulations, and standards, as well as summaries and commentary on landmark BV cases—including Jelke and McCord. Save time and spare yourself the frustration of mining the Internet or thumbing through print sources for these key materials. The BV Sourcebook puts everything you need in one place! Table of Contents Introduction Chapter 1—Internal Revenue Code § 409A. Inclusion in gross income of deferred compensation under nonqualified deferred compensation plans § 1060. Special allocation rules for certain asset acquisitions § 1374. Tax imposed on certain built-in gains § 2031. Defi nition of gross estate § 2032. Alternate valuation § 2036. Transfers with retained life estate § 2044. Certain property for which marital deduction was previously allowed § 2511. Transfers in general § 2512. Valuation of gifts § 2701. Special valuation rules in case of transfers of certain interests in corporations or partnerships § 2702. Special valuation rules in case of transfers of interests in trusts § 2703. Certain rights and restrictions disregarded § 2704. Treatment of certain lapsing rights and restrictions § 6501. Limitations on assessment and collection § 6662. Imposition of accuracy-related penalty on underpayments Chapter 2—Treasury Regulations Sec. 20.2031-1 Defi nition of gross estate; valuation of property Sec. 20.2031-3 Valuation of interests in businesses Sec. 25.2703-1 Property subject to restrictive arrangements Sec. 25.2703-2 Effective date Sec. 25.2704-1 Lapse of certain rights Sec. 25.2704-2 Transfers subject to applicable restrictions Sec. 25.2704-3 Effective date Sec. 301.6501(c)-1 Exceptions to general period of limitations on assessment and collection back to top Chapter 3—Revenue Rulings and Procedures 59-60 Valuing Shares of Capital Stock of Closely Held Corporations for Estate and Gift Tax Purposes 65-192 Applying 59-60 to Income Tax Valuations 65-193 Modifi cation of 59-60 Regarding Tangible and Intangible Assets 68-609 Excess Earnings Method 77-287 Valuation of Restricted Stock 83-120 Closely Held and Preferred Stock 85-75 Penalty for Valuation Overstatement 93-12 Closely Held Interests and Family Transfers 98-34 Compensatory Stock Options Rev. Proc. 2003-51 Allocation of lump sum purchases of a business 2006-96 Guidance Regarding Appraisal Requirements for Noncash Charitable Contributions Chapter 4—Landmark Cases Index of Cases by Topic 4-A Astleford v. Commissioner Astleford Has it All: Latest Tax Court Case on FLP Discounts, Data, and More Dallas v. Commissioner Tax Court Declines to Tax-Affect S Corp In Gift Transfer Case Tax Court Rejects Tax-Affecting of S Corporation Daubert v. Merrell Dow Pharmaceuticals Comparing the Butler-Pinkerton Model to Traditional Methods Under Four Daubert Criteria ‘Intrinsic Value’ Doesn’t Meet Daubert Criteria Valuation Experts Required To Have Clear Credentials, Experience, and Methods Experienced (but Uncertifi ed) Expert Caught in Deposition Gross v. Commissioner (II) Daubert issue rears its ugly head in Gross case Estate of Jelke v. Comm’r Jelke Overruled: 11th Cir. Approves 100% Discount For Imbedded Capital Gains Divorce Court Analyzes Built-In Capital Gains and Net Asset Value in Divorce Delaware Open MRI Radiology Associates, P.A. v. Kessler, et al Must-read Opinion from Chancery Court on Tax Affecting, DCF Discounts, and More Kumho Tire Co. v. Carmichael 4-30 Federal cases challenge fi nancial experts on basis of Daubert/Kumho tests State courts consider application of Daubert/Kumho tests to appraisal experts Implications of Kumho for Business Appraisal Experts Daubert/Kumho state challenges to appraisal experts Mandelbaum v. Commissioner Minority Share Gifts: Court Finds 30% Discount for Lack of Marketability Tax Court provides list of factors to consider in determining the size of a marketability discount McCord v. Commissioner of Internal Revenue 5th Circuit Reverses McCord, Confi rming Original Valuation Of Marketability Discounts McCord Reversed: Fifth Circuit Affi rms Use of Fixed Dollar Gifts of Limited Partnership Interests After McCord: The Future Of FLP Valuations and Discount Determinations In re Med Diversifi ed, Inc. BV on Trial in Bankruptcy? New York Court Excludes Appraisal as ‘Junk Science’ Where Perceived Bias Infects Entire Valuation, Expert Excluded as Unreliable under FRE 702(3) NY Bankruptcy Court Confi rms Valuation of Customer Lists, With High Praise for Valuator Estate of Mirowski v. Commissioner Good News on FLP and LLC Planning—Appraisals Have Value! back to top Chapter 5—Additional Cases New Cases in 2010 Edition Estate of Litchfield v. Commissioner Gaskill v. Robbins Sieger v. Zak Estate of Jorgensen v. Commissioner Peterka v. Dennis Estate of Miller v. Commissioner Chick-Fil-A v. CFT Development, LLC MDG Internat’l v. Australian Gold, Inc. Fleischmann v. Fleischmann Inzer v. Inzer Keller v. United States In re American Home Mortgage Holdings, Inc. Murphy v. U.S. In re TOUSA, Inc. Veritas Software Corp. v. Commissioner In re Marriage of Devries Grelier v. Grelier In re Sunbelt Beverage Corp. Shareholder Litigation. Estate of Black v. Comm’r Lemmen v. Lemmen Amaraneni v. Amaraneni Dickert v. Dickert Mistretta v. Mistretta Mandell v. Mandell Heckerman v. Commissioner Estate of Godley v. Commissioner (II) Estate of Abraham v. Commissioner First Circuit Affirms FLP Case Against Taxpayer Remainder Interest in FLP Units Argument Rejected Patricia M. Adams, et al. v. United States of America Assignee Interest Not Subject to Liquidation Rights Estate of Baird v. Commissioner Hypothetical Partition Discount is Insufficient for Fractionalized, Non-controlling Interests Fully Documented and Supported Appraisal Reports Helped Put IRS on Notice That Its Litigation Position Was Unsupportable Estate of Berg v. Commissioner Estate of Berg v. Commissioner Bergquist v. Commissioner Tax Court Rejects Appraisal of Donated Stock for Incorrect Premise of Value Bernier v. Bernier Debate over Tax-Affecting Plays Out in New Divorce Case Estate of Bigelow v. Commissioner FLP Disregarded Where Decedent Retains Insuffi cient Funds Section 2036(a) Applied to Recapture theValue of Real Property Transferred to FLP Estate of Brocato v. Commissioner 11% Blockage Discount Applied in Apartment Valuations Crescent/Mach I Partnership v. Turner Del. Chancery’s Preference For DCF Turns On Credible Projections Estate of Deputy v. Commissioner Tax Court Accepts Negative Industry Risk Premium and Unique Combined Discount Matrix Income Approach Used to Value Boat Manufacturer Derby v. Comm’r Tax Court Examines Charitable Deduction Estate of Dunn v. Commissioner (I) Equipment Company Valuation Turns on Asset- and Earnings-based Values Heavy Equipment Rental Company Valued Using Weighted Earnings and Asset Approaches Estate of Weinberg v. Commissioner Tax Court Rejects QMDM and Use of Single Comparable Quantitative Marketability Discount Model Determined Unhelpful Estate of Ray A. Ford v. CIR Holding Company’s Valued Using Net Asset Value Richard S. Gesoff v. IIC Industries Inc. Small-Stock and Company Specifi c Risk Premia Considered in Fair Value Analysis Estate of Gimbel v. Commissioner Tax Court Determines Methodology, Discounts for Large Block of Public Shares Gow v. Commissioner (II) Fourth Circuit Affi rms Gow v. Commissioner Voting Trust Not a Factor in Determining Fair Market Value Estate of Green v. Commissioner DLOM major issue; Tax Court ‘splits the baby’ Fair Market Value of Minority Interest in a Closely Held Bank Determined Gross v. Commissioner IRS and Taxpayer Agree to 35% DLOM— if FLP Transfers Pass ‘Indirect Gift’ Tests Hackl v. Commissioner Seventh Circuit Affi rms Tax Court; Gifts Were of Future Interests Seventh Circuit Affi rms Decision Denying Application of Sec. 2503 Exclusion Where the Restrictions on Transferability Attached to LLC Units Are Severe Hansen v. 75 Ranch Company Montana Dissenter Awarded Double Amount Originally Offered Harmon v. Harmon Buy-sell Agreement One Factor in Value of Medical Practice Value of an Interest in a Medical Practice Is Not Set by the Buy-Sell Provision Estate of Heck v. Commissioner Tax Court Rejects Use of Single ‘Similar’ Comparable S Corp. Valued Using DCF Method Highfi elds Capital, Ltd. v. AXA Financial, Inc. Del. Chancery Rejects DCF Analysis in Insurance Co. Appraisal Estate of Hillgren v. Commissioner Tax Court Disregards FLP That is Disregarded by Taxpayer Sec. 2036(a) Applied to Look Through an FLP Holman v. Commissioner Tax Court Takes Novel Approach to DLOM Holding Period in Holman Huber v. Commissioner ‘Friends and Family’ Gifts of Private Stock Support 50% DLOM ‘Arm’s-Length’ Determined Using Morrissey Test Estate of Hurford v. Comm’r Latest FLP Case Lists ‘Bad Facts’ to Avoid Estate of Jameson v. Commissioner Fifth Circuit Acknowledges Substantial Built-in Tax Liability on Timber Property Janda v. Commissioner Tax Court Considers QMDM and Restricted Stock Studies in Determining Discount for Lack of Marketability Quantitative Marketability Discount Model Rejected Kimberlin v. Comm’r. IRS Stumbles on Characterization and Valuation of Stock Warrants Kohler et al. v. Commissioner Kohler: Textbook Valuation of Large Closely-Held Leads to Total Victory for Taxpayer Tax Court Emphasizes Importance of Valuation Credentials and Familiarity with the Subject Company LabelGraphics, Inc. v. Commissioner (II) Ninth Circuit Affi rms Tax Court Reasonable Compensation Ruling Litman v. United States Litman a New Landmark Among Cases Considering Restricted Stock Discounts 5-97 Mad Auto Wrecking v. CIR Tax Court Provides List of Factors to Consider in Determining the Appropriate Amount of Owners’ Compensation Martin Ice Cream Company y. CIR Sale of Subsidiary after Split-off Does Not Establish Value of that Subsidiary Estate of Mellinger v. Commissioner Frederick’s of Hollywood Stock Not Aggregated for Valuation; 25% Blockage Discount Applied Aggregation and Blockage Considered Estate of Mitchell v. Commissioner (II) Ninth Circuit Vacates and Remands Tax Court’s Valuation in Mitchell Normandie Metal Fabricators, Inc. v. CIR Hypothetical Investor Test Used to Determine Officers’ Reasonable Compensation Peracchio v. Commissioner Tax Court Displeased With All Experts’ DLOC and DLOM Analyses Limited Partnership Units Valued Estate of Lillie Rosen v. Internal Revenue Service ‘Classic’ FLP Case by Judge Laro Finds No §2036 Estate Tax Exception Salt Lake Tribune Publishing Co., LLC v. Management Planning, Inc. Appraisal ≠ Arbitration; a Court May Review Buy-Sell Valuation for Certain Errors Estate of Simplot v. Commissioner (I) Tax Court Accords Superpremium to Small Voting Block; Allows Deduction of 100% of Trapped-in Capital Gains Tax Voting Privileges Valued as a Percentage of the Company’s Total Equity Value Comments on the Reversal of Simplot Stone v. United States Do BV Methods Apply to Determining Discount for Fractional Interest in Art? Strangi v. Commissioner Fifth Circuit Affi rms Tax Court’s Application of § 2036 to FLP Assets Bona Fide Sale Exception to Sec. 2036 Analyzed Temple v. United States Latest Court Looks at DLOM: Assumptions Are Everything Standard Valuation Discounts Considered Estate of Thompson v. Comm’r IRS Burden of Proof Does Not Obviate Errors In Taxpayer Valuation FLPs Disregarded—2036(a)(1) Applied Once Again! Third Circuit Addresses Sec. 2036(a) Exception in FLP Case Estate of True v. Commissioner Buy-sell Agreements are Testamentary Devices Univ. of Pittsburgh v. Townsend Federal Court Clarifi es Rule on Discovery of Draft Valuation Reports Wechsler v. Wechsler Appeals Court Affi rms Dollar-for-Dollar Discount in Divorce back to top Chapter 6—Standards AICPA Valuation of a Business, Business Ownership Interest, Security, or Intangible Asset AICPA Code of Professional Conduct: Section 101—Independence TOC-8 BVR’s Business Valuation Sourcebook AICPA Code of Professional Conduct: Section 102—Integrity and Objectivity AICPA Code of Professional Conduct: ET Section 201—General Standards AICPA Code of Professional Conduct: ET Section 202—Compliance with Standards AICPA Code of Professional Conduct: Section 301—Confi dential Client Information AICPA Code of Professional Conduct: Section 302—Contingent Fees AICPA Code of Professional Conduct: Section 501—Arts Discreditable ASA Principles of Appraisal Practice and Code of Ethics ASA Business Valuation Standards IBA Business Appraisal Standards FASB Summary of Statement No. 123 (revised 2004) FASB Summary of Statement No. 141 (revised 2007) FASB Summary of Statement No. 142 FASB Summary of Statement No. 144 FASB Summary of Statement No. 157 FASB Summary of Statement No. 159 NACVA Professional Standards Chapter 7—Appendix of Key Valuation Articles and Other Material 4th Quarter 2008 Economic Outlook Update™ Reporting Standards Update: What all BV Analysts Must Know Courtesy of the IRS: 22 Ways to Avoid Appraisal Missteps Summary of FAS 157, Fair Value Measurements Federal and Regional Reporter’s List Goodwill Hunting in Divorce BVR’s Professional Association Directory 2009 Edition back to top
		Author(s): Publisher: Business Valuation Resources, LLC Published: 7-2010 Type: Guide