Jay Darby (Greenberg Traurig, Boston) is quoted in the current issue of CCH's Business Valuation Alert as suggesting that students "think of the Internal Revenue Code as a sophisticated partnership agreement between the government and every U.S. person...the bottom line is that the US government is your mandatory partner in all economic and business endeavors. It is quick to claim a share of profits in good years, but far less willing to share losses. The government is also able to change the terms of your partnership agreement at any time without your consent." Darby suggests likely tax minimization strategies, if known to the business valuator (he cites equity swaps where owners "trade up" to equity in a larger business), could influence an analysis.