Join Barry Sziklay for important 2021 income and transfer tax valuation cases as well as the valuation aspects of the adequate disclosure regulations required to report a gift for federal transfer tax purposes and start the statute of limitations running. Internal Revenue Code (IRC) Chapter 14 valuations, Special Valuation Rules §§ 2701-2704, will be addressed in a summary fashion given the complexities of the rules required for a valuation to meet the requirements of Chapter 14. A very important transfer pricing (§482 Allocation of Income and Deductions Among Taxpayers) case involving billions of dollars of assessed taxes will be covered. In-depth coverage of Chapter 14 valuation and transfer pricing is beyond the scope of this presentation. Taxpayers in various courts including courts of appeal are currently contesting some of the issues covered in the presentation and handout materials, so practitioners are urged to keep that fact in mind as they consider the handout materials. Practitioners are, therefore, urged to shepardize any case upon which they intend to rely or consult competent legal counsel, in circumstances in which the current state of the law may be unsettled. 

• List the most important cases of the last year or so with regard to income, gift, and estate tax valuations and how the courts look at valuations, discounts, and premiums in various situations.
  
• Restate potential criticisms of widely accepted valuation practices and how they may best “bulletproof” their reports to address such potential criticisms. 
  
• Describe how courts can challenge the underlying assumptions and conclusions of very experienced appraisers.