Hempstead & Co. has published "Estate of Gallagher is a Valuation Tutorial." The article emphasizes the importance of providing the court with a
clear and convincing explanation of the assumptions and arguments you
have employed in carrying out a business appraisal. It discusses the recent Tax Court summary opinion Estate of Gallagher v. Commissioner, TC Memo. 2011-148) in which IRS attorneys objected to an adjustment that their own expert had conceded and that of the five valuations conducted. The Court's valuation was closest to the value on the return as filed.
Posted by William Alan Nelson II, Associate Editor, Wealth Strategies Journal

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