The valuation impact of the unrealized capital gains tax liability on appreciated assets of closely held companies has been an area of controversy for nearly 30 years. After years of fighting the taxpayer on this particular issue, the Internal Revenue Service has been more willing to recognize this contingent liability and its impact on the value of closely held stock. In the same respect, the Tax Court has reviewed this issue in various cases over the years and has clearly recognized that
ARTICLE ACCESS REQUIRED
Please Log in if you are currently a Trust&Estates subscriber, or select DAYPASS for our new 24 hour access (nominal fee required).
If you are interested in unlimited article access for one year, please select Annual Subscription below.