This and other questions continue to bedevil estate and gift tax practitioners with clients who own businesses. Business appraisers whose valuations support these clients’ claims are being challenged more frequently than ever. For example: are the guideline public company method and its use of comparable entities/transactions under heightened scrutiny by the Tax Court? And what about the income approach—how do BV experts prove the credibility of their normalization adjustments, reliance on management projections, calculation of the cost of capital (including the discount rate); and of course, that continuing tempest in the Tax Court, determination of marketability discounts? The IRS’s fractional interest model continues to cause quite a stir, as does the ever-present specter of a Daubert challenge to expert testimony and valuation reports.
BVR’s fourth annual Tax Summit started today in its new, interactive web format. Four programs on the intersection of valuation and tax law present Tax Court judges, expert appraisers, attorneys, and IRS representatives, including:
Estate of Gallagher: How the Court Sees the State of Business Valuation, Today, Thursday, Oct. 20, featuring Chris Mercer and Paul Hood;
Lawyers Roundtable: What Attorneys Are Seeing in Tax Court & What They Are Looking For in Expert Financial Witnesses, Friday, Oct. 28, featuring moderator Jay Fishman and attorneys Stephanie Loomis-Price and Edward Robbins;
Judges Roundtable: View From the Bench, Friday, Nov. 4, featuring Hon. David Laro, Hon. Joseph Robert Goeke, Hon. Julian I. Jacobs, all from the U.S. Tax Court, and moderator Jay Fishman;
Valuing a Majority Fractional Interest, Friday, Nov. 11, featuring Neil Mills-Mazer (IRS).
Register for all programs in the series (at a discount), or attend each separately.