Noncertified occasional valuer is not a qualified appraiser, per Tax Court
For tax purposes, the most important requirement under the qualified appraisal rules is that the valuation be done by a qualified appraiser. But how much experience is enough? A new case gives some guidance.
Advanced Topics and Case Studies When Valuing Family Limited Partnerships and LLCs
As professional methodology has advanced and tax court cases have confirmed, employing analytical techniques to value family limited partnerships/LLCs using the income and market approaches allow appraisers to determine an accurate value objectively. Certain types of partnerships may be considered complicated. This webinar will focus on valuing more complex FLPs using case studies. Mr. Johnson will present empirical data that support the use of these objective appraisal methods and share his opinion on current issues ...
Prince Estate and IRS Embroiled in Fierce IP Valuation Dispute
Back in January, BVWire ran a news item on a recent article from the Star Tribune. The article states that the executor of the estate of Prince, the late world-famous rock star, and the Internal Revenue Service are currently locked in a fierce estate and gift tax dispute. The IRS argues the executor has seriously undervalued the estate, and the executors claim the IRS’ calculations “are riddled with errors.”
NICE Value! How to Deploy the Non-Marketable Investment Company Evaluation Method
When it comes to valuing minority interests in family investment entities such as family limited partnerships, business valuation professionals have not often used the income approach. However, in three recent Tax Court cases, the income approach was prominently featured, and, in one case, it was clearly the deciding factor in the court’s decision. Join William Frazier to learn about the nonmarketable investment company evaluation (NICE) method. Learn its origins, what it doesn’t replace, and how ...
Power Panel: Live Expert Answers for Today’s Tough BV Questions
What is in store for 2021? While we don’t have a crystal ball, we do have the next best thing. Thought leaders Jay Fishman, Jeff Tarbell, Michelle Gallagher, and Ken Pia are on hand to answer your questions on what is changing, trends within the profession, and thought processes behind tackling tough problems. What’s more, if you send in a video of yourself asking the question, you will get free admission to the session. Use ...
Masterclass in Normalizing Compensation
Three nationally known experts will explain how to determine reasonable compensation amounts. The principal author of the Job Aid, Mike Gregory, will explain the “IRS Job Aid on Reasonable Compensation” and share case studies with many tips and traps. One of the foremost national experts on reasonable compensation, Stephen Kirkland, will share insights and sources to help determine reasonable compensation for your clients. Paul Hamann will show how easy it is to use RCReports to ...
BVLaw Case Update
Join Jim Alerding, a veteran valuator, and Sylvia Golden, BVR’s legal editor, for a discussion of some of the most consequential recent valuation decisions. This selection of state and federal cases includes two key state court rulings on the use of discounts in valuing minority interests in buyback situations, a state court decision on the admissibility of calculations of value in divorce proceedings, an expansive statutory appraisal ruling involving a public company from a North ...
Tax Court revaluation means big-time savings for taxpayer
In an estate tax dispute that has lasted for over five years, the Tax Court recently revalued the decedent’s minority interest in an Oregon family business by order of the 9th Circuit Court of Appeals. The recalculation proved a boon to the taxpayer.
S Corp model now in Tax Court
At the recent NYSSCPA business valuation conference in New York City, Daniel Van Vleet (Stout Risius Ross) told the audience that the Van Vleet model (S corporation economic adjustment model) is being used for the first time in a pending U.S. Tax Court case. What’s more, both the IRS and the taxpayer are using it in this case, says Van Vleet.
NACVA's star-studded silver anniversary conference
Shannon Pratt, Roger Grabowski, Jim Hitchner, Nancy Fannon, and the Honorable Judge David Laro of the Tax Court are just a few of valuation thought leaders dubbed by NACVA as “industry titans” who gave presentations at the organization’s 25th anniversary conference in San Diego
Practice tips for valuation experts from tax court insiders
Judge Laro reminded experts to guard against domineering attorneys who insist on reviewing draft opinions and seek to nudge an expert into achieving a predetermined result. Valuation experts need to know the discovery rules (Rule 26 of the Federal Rules of Civil Procedure) rather than assume that all of the attorney-expert communication is protected.
Can the IRS subpoena your work papers, even after the taxpayers have paid the deficiency?
An Idaho couple claimed nearly $1.5 million as a charitable contribution deduction on their federal tax returns relating to the granting of a conservation easement. The IRS summoned the taxpayer’s appraiser to provide evidence related to the easement valuation, including all his work files. Based on advice of the taxpayer’s attorney, the appraiser refused the summons, asserting the attorney-client privilege and work-product protections.