IRS to issue BV standards for comment
By the middle of May, the IRS will issue draft valuation standards to submit to the various appraisal organizations for comment. Howard A. Lewis , the new IRS Engineering Program Manager, made this a ...
FLP trilogy a victory for taxpayers
As discussed in my December 2000 Editor's Column, I requested that several members of our Editorial Advisory Board provide me with comments regarding the recent Tax Court trilogy of FLP cases for a sy ...
FEDERAL ESTATE AND GIFT TAXATION
n FEDERAL ESTATE AND GIFT TAXATION , Stephens, Richard B., Guy B. Maxfield, Stephen A. Lind, and Dennis A. Calfee. Warren, Gorham & Lamont of the RIA Group , 31 St. James Avenue, Boston ...
Highlighting the ASA Advanced BV Conference
With over 300 people at the American Society of Appraiser's Advanced BV Conference in Philadelphia in November, there were enough informative presentations to satisfy the attendees' needs. Here are so ...
Expert takes issue with Borgatello case abstract
We are using this month's Editor's Column to bring to you a Reader/Editor Exchange in which the estate's expert takes issue with the Borgatello v. Commissioner court case abstract, found in the Octo ...
Fixed growth and present value rates not challenged
In a novel approach to the development of a marketability discount for a real estate holding company, the U.S. Tax Court in Borgatello (see page 16 of this issue) assigns numerical values to ...
IRS proposes new rules for reporting gifts; Statute of limitations welcome, but some proposed requirements difficult
Certainly taxpayers welcome the provision of the Taxpayer Relief Act of 1997 that starts a three-year statute of limitations on revaluation when a proper gift tax return is filed, whether any gift tax ...
Adequate Disclosure of Gifts Final Regulations
FEDERAL REGISTER Vol. 64, No. 232 Rules and Regulations DEPARTMENT OF THE TREASURY Internal Revenue Service (IRS) 26 CFR Parts 20, 25, 301 and 602 [TD 8845] RIN ...
Valuing a Business 4th edition now out; Reflects growing consensus
The fourth edition of Valuing a Business is finally available, and I am quite pleased with the resulting product. The very extensive amount of updated and new material is a testament to the ...
Partnership discount info in a click
Partnership Profiles Minority Interest Discount Database , Partnership Profiles, Inc. , (800) 634-4614, Available online or CD-ROM. $295. &nbs ...
DISCLOSURE SETS TIME LIMIT ON IRS GIFT REVALUATION
n DISCLOSURE SETS TIME LIMIT ON IRS GIFT REVALUATION , Oliver, Joseph R., and Granstaff, Charles A. Tax Strategies , Volume 62, Number 1, January 1999. This article focuses on estate and gif ...
Fiduciary and Valuation Issues Arising from Eyler v. Commissioner
n FIDUCIARY AND VALUATION ISSUES ARISING FROM EYLER V. COMMISSIONER , Gould, Susan E., and Gregory K. Brown, Esq. Willamette Management Associates Insights , Spring 1999. This article is av ...
The IRS and Family Limited Partnerships—Issues and Opinions
n The IRS and Family Limited Partnerships—Issues and Opinions , Clay, Kimberly E. BizVal.com , Vol. 11, No. 3, 1999. Kimberly Clay explains that even though the IRS allows discounts for mino ...
Current Internal Revenue Service appraisal practices "violate the American taxpayers' right to uniformity"
The current appraisal practices of the Internal Revenue Service systematically violate the American taxpayers' right to uniformity in the determination of tax liability under Article 8 Section I of ...
ABA panel calls for elimination of ancillary business restrictions
By Shannon Pratt and Yazhi Li The theme of the ABA Tax Section Plenary Session was whether to do away with the rules prohibiting law firms from engaging in ancillary businesses with non-lawyer ...
IRS releases recommendations on valuation policies
It has long been known that there are serious deficiencies in the Internal Revenue Service's valuation policies. There is a lack of cohesiveness in valuation reporting requirements and an absence of u ...
IRS cannot stop "even many of the most outrageous case"
"I.R.S. Sees Increase in Evasion of Taxes on Gifts to Heirs," David Cay Johnston , The New York Times , April 2, 2000, Sec. 1, p. 1, col. 6. David Cay Johnston draws attention to the fact that Ameri ...
IBA highlights include FLP settlements, database comparisons
The 2000 IBA annual conference, held Feb. 3-5 in Phoenix, included a variety of "hands-on useful" presentations and panels. Highlights of a few of the presentations, award recipients, and audiotape in ...
Lost profit damages analysis offers a natural extension for business appraiser skills
Business appraisers often find themselves in a litigation setting. After all, much of the work that we do has two distinct "sides," whether it is a divorce, a shareholder dispute, or a matter before t ...
1999 in review: What we learned in a busy year
My 30 th year in the business valuation profession ( see December 1999 BVU , p.1) was an active one in terms of development in the profession. Here are some of the highlights: l 1999 was o ...
IRS publishes final regulations for "adequate disclosure" of gifts
Responding to proposed gift tax regulation comments, on Dec. 3, 1999, the Internal Revenue Service published final regulations for the Adequate Disclosure of Gifts (64 Federal Register 67767). The ...
Expert witness for IRS attacks size premium part of discount rate
At every one of the several merger & acquisition meetings that I have attended in recent months, both buyers and intermediaries consistently say that smaller companies usually sell at lower multip ...
IRS audits family limited partnerships
A client of mine received the attached questionnaire from the Internal Revenue Service concerning preparations for a possible audit of his FLP. I am told that a number of FLPs have received ...
IRS proposes regs to start gift tax statute of limitations
Adrian presents a straightforward explanation and discussion, from a business appraiser's point of view, of the requirements and pitfalls that the IRS proposes to impose in order to trigger the three ...
Sale of Nonprofit Facility Results in Inurement to Buyers; Court Refuses to Receive IRS Expert's Report in Evidence
According to the court, "The primary issue for decision is whether petitioner's tax-exempt status should be revoked."