Most critical decisions involve financial considerations. Let Morrison Valuation & Forensic Services provide you with credible and timely information necessary to make those decisions. We are a full service business valuation and forensic accounting firm providing business valuations for financial reporting, estate and gift, and sale and purchase purposes; forensic accounting investigations for civil and criminal matters; and consulting and testifying expert witness services in commercial disputes. Members of the firm frequently are also appointed in state and federal courts as a court-appointed neutral.
Estate of Richmond, 2014 Tax Ct. Memo LEXIS 26 (Feb.11, 2014). Taxpayers (and now tax preparers and business appraisers) are subject to significant penalties assessed by the IRS for understatement of tax liability and obligation. This includes when, for example, the values reported in gift and estate federal tax returns for ownership interests are determined to be understated, even if based on the analysis and opinions of a professional.
In this case, an estate tax return was filed with a reported value of $3.15 million for a non-controlling interest in a family limited partnership. The value was based on a draft opinion by a CPA. The IRS issued a deficiency notice and teh taxpayer appealed.
At trial, the taxpayer presented expert testimony of a credentialed business valuation professional. That expert valued the subject interest at approximately $5 million. (NOTE: The IRS's expert valued the interest at $7.3 million). The Court finally held that the value was $6.5 million.
The IRS sought substantial misstatement penalties (reported value o 65% or less of the "accurate value") from the taxpayer. In its defense, the taxpayer argued that it acted "in good faith and with reasonable cause" when it used the value recorded in the draft valuation by the CPA. However, the Court ruled against the taxpayer holding that the CPA was not a "certified appraiser".
To read the Tax Court Memo, Click Here.
To read more about teh IRS's definitions of "qualified appraiser" and "qualified appraiser", Click Here.
MorrisonVFS is pleased to announce a new relationship with the Central Florida Zoo & Botanical Gardens located in Sanford, Florida. MorrisonVFS is now the sponsor of the Flying High! Bird Show that features appearances and performances by owls, hawks, and other exotic birds. The shows take place at noon on weekend days and on holidays.
Beautiful red-shouldered hawk
Eye-to-eye with a predator: a full-grown screech owl
The majestic great horned owl