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In September 2009 the Internal Revenue Service (IRS) published "Discount for Lack of Marketability: Job Aid for IRS Valuation Professionals." This document, "Developed by Engineering/Valuation Program DLOM Team," provides guidance for IRS agents and engineers on areas of application and analysis of common methods of determining discounts for lack of marketability (DLOM) as well as the data that goes into these determinations.
In "What Business Valuators Need to Know When Preparing a DLOM for the IRS," expert appraiser Michael Gregory, formerly of the IRS, and chief author of the Job Aid, joins BVR to discuss IRS interpretations of DLOM methodologies. From knowing how to work with the IRS to what to expect of IRS reviews and attacks on DLOM determinations, Gregory will cover the key points to presenting and obtaining information, and, most importantly, defending the valuation.
Program Agenda
Understand the IRS Organization
Discounts for Lack of Marketability and the IRS DLOM Job Aid
Benchmarking Approaches
Restricted Stock studies and Databases
Pre-IPO Studies
Mandelbaum Factors
Securities-Based Approaches
Analytical Approaches
Bajaj, Denis, Ferris and Sarin
QMDM
Original Job Aid and Updated Comments on Other Approaches
Summary Approach Recommendations
How to Work with the IRS
Learning Objectives
Understand the IRS Organization
Understand the US Tax Court commentary of approaches
Learn how the IRS interprets DLOM determination methods, their application, and their analysis
Learn tips to assist in Preparing a DLOM for the IRS
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