IRS Must Assign Zero Value To Unprofitable Intangibles–And Other Lessons from Recent Caracci Reversal

Business Valuation UpdateVol. 12 No. 11
November 2006

Summary

Buried in the recent Fifth Circuit reversal of Caracci v. Commissioner is the broad and potentially controversial holding that the IRS is compelled to assign a value of zero to the intangible assets of an enterprise that was unprofitable prior to a dispos ...