In Berquist v. Commissioner, Judge Swift Finds a Company’s Pending Liquidation is Relevant and Foreseeable. The Tax Court valued closely-held stock in an anesthesiology practice donated to a hospital for charitable contribution purposes at its liquidation value since the anesthesiology practice would no longer exist after the physician-stockholders were consolidated into a newly-formed umbrella physician management company.  The donors valued the practice at $401.79 per share under the going concern premise of value.  The respondent determined a fair market value of $37.00 per share under the liquidation premise of value.  The Judge cited one key factor that determined his ruling. …