Five factors the IRS relies on in reasonable comp. cases

BVWireIssue #52-4
January 24, 2007

Last week we heard from IRS Engineering Manager Robin Ruegg (Bloomington, IN) regarding her opinions on compensation data sources and surveys; this week, she points us to the “five factors” used in Elliots v. Commissioner, which (in her opinion) the IRS “often uses” to develop its reasonable compensation cases. For a copy of this landmark 1983 case—just one of over 1,600 federal and state, valuation-specific decisions available to subscribers of the BVLaw™ database at, click here.

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