What Role for Revenue Ruling 59-60 Factors in Valuing Closely Held Business?

Business Valuation UpdateVol. 21 No. 4
Legal and Court Case Update
April 2015
3433 Heating Equipment, Except Electric and Warm Air Furnaces
333414 Heating Equipment (except Warm Air Furnaces) Manufacturing
contract
damages, lost profits, daubert, expert testimony, cash flow, closely held corporation, fair market value (FMV), reliability, revenue rulings (RR)

J&M Distrib., Inc. v. Hearth & Home Techs., Inc.
2015 U.S. Dist. LEXIS 2314
January 9, 2015
US
Federal Court
Minnesota
United States District Court
Michael DeProspero (plaintiff); Melissa Snelson (defendant)
Nelson

Summary

Expert’s use of Revenue Ruling 59-60 for valuation of closely held business and for damages calculation does not render opinion inadmissible under Daubert, court says, noting that scope of revenue ruling goes beyond valuation of estate and gift taxes.

See Also

J&M Distrib., Inc. v. Hearth & Home Techs., Inc.

Expert’s use of Revenue Ruling 59-60 for valuation of closely held business and for damages calculation does not render opinion inadmissible under Daubert, court says, noting that scope of revenue ruling goes beyond valuation of estate and gift taxes.