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Dissecting the IRS Job Aid on S Corporation Tax Affecting

Background and Objectives of the Job Aid (Part 3 of 3) In the third article of this three part series, the author discusses the remaining portions of the Job Aid, specifically, the Discussion and Analysis Section of the Job Aid which addresses: Evidence-Based Valuation Analysis, Theory-Based Valuation Analysis, and Weighting of Factors and Approaches and shares his views on the value and limits of this docu ...

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Dissecting the IRS Job Aid on S Corporation Tax Affecting

Background and Objectives of the Job Aid (Part 2 of 3) In the first of this three-part series, the leading cases involving tax-affecting where analyzed; those cases discussed included: Gross, Wall, Heck, Adams, Dallas, Gallagher, Korbel, and Guistina. This second part analyzes the first two parts of the Job Aid by section, the “Executive Summary” and first three subsections of the “Discussion and Analysis”, ...

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Dissecting the IRS Job Aid on S Corporation Tax Affecting

Background and Objectives of the Job Aid (Part 1 of 3) The release of this series of Job Aids has been hailed by many as a new era of communication and understanding between the Internal Revenue Service, taxpayers, and practitioners. However, in the opinion of this author, and others, releasing these additional documents in such a formal manner seems to be an attempt to influence practitioner behaviors in s ...

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How the IRS Values Non-Controlling Interests in S Corps

With Commentary by Original IRS Champion Leading valuation practitioners have proposed various models to guide practitioners valuing controlling and non-controlling interests. The published Tax Court cases—precedents—have favored the position of the IRS. The author suggests that is not surprising. In a soon-to-be released book, Michael Gregory highlights the importance of a new Job Aid focused on valuation ...

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