Lessons to be learned by Valuators from Cavallaro v. Commissioner Cavallaro v. Commissioner holds some valuable lessons for valuation experts. Following a tax-free merger of two companies owned between different family members, the children of the petitioners (and owners of one of the companies, pre-merger) received 81 percent of the stock in the merged entity. Differences arose between one set of accountants and Hale & Dorr, the law firm that assisted the founders with estate planning. The key issue was whether valuable technology was owned by the company controlled by the parents or the company owned by the children. The…