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 specific practice areas without statutory support. As was the case with the earlier Job Aid on Discounts for Lack of Marketability, the newest Job Aid contains little new information. Predictably, the position…
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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 of S corporations.