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With a special focus on the recent Aaron U. Jones (USTC TCM 2019-101) case regarding tax affecting an S corp and a partnership, this workshop is the best way to get IRS insights short of going into litigation. Get real insights on how to avoid and what to do if working with the IRS on business valuation issues at all levels. Join Mike Gregory as he dives into conflict resolution (with assistance from the Collaboration Effect) to help you get the best outcome. Then the emphasis will shift to real-world interactions with the IRS on exam, appeals, and litigation with current examples you can learn from for your practice. Smart valuation professionals learn from their IRS engagements—brilliant ones learn from this workshop.
Program Agenda
Identify key elements related to conflicts and collaboration
Explain elements of alternative dispute resolution with the IRS
The IRS Big Picture
Job Aids
Two Real World Examination Examples
to Set the Tone
Discount for Lack of Marketability
Submitting a BV Report to the IRS
How to Prepare Administratively
How to Prepare Technically
IRS Focus
Examination on Business Valuations
Large Business and International (LB&I) Assets > $10 M
Small Business Self Employed (SBSE) Assets < $10M
Tax Exempt and Governmental Entities (TEGE)
Appeals and Business Valuations
Counsel and Business Valuations+
Official Alternative Dispute Resolution
and the IRS
Role of IRS Examiner and Role of the Business Valuer
Who is the Decision Maker on an Examination?
Working Cases at the Examination Level
Does Geography Matter?
Does Timing Matter?
Most Common Adjustment Areas by IRS Business Valuers
Evaluate insights from the Aaron U. Jones case and tax affecting S-Corps
Case background
Operations and Management
Estate Expert Determination
IRS Expert Determination
Rebuttal
Valuation issues
Operating versus holding company
Tax Affecting
Market approach commentary
Company Debt
DLOM
Conclusion
Apply lessons learned from real world examples of BV cases with the IRS
Examples
Lund Case
Judges comments
Appeals process
Litigation
Take Away Info
Learning Objectives
Identify key elements of neuroscience related to conflicts and collaboration
Explain elements of alternative dispute resolution with the IRS
Evaluate insights from the Aaron U. Jones case and tax affecting S-Corps
Apply lessons learned from real world examples of BV cases with the IRS
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