The discounting is appropriate because the interest lacks control. We are writing in reply to your summary of the Borgatello case in the October 2000 issue of Business Valuation Update . Unfortunately, you have misrepresented certain of our valuation positions and mischaracterized what the Tax Court had to say about my testimony.
Lawyers often comment that good cases make bad law.
By definition, a judge s opinion is good law. Unfortunately, a judge s opinion can be based on bad economics. Your readers might find it of interest. The Service has announced that it intends to revise the standards for tax shelter opinions, as well as general practice standards contained in Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries and Appraisers before the Internal Revenue Service. Appraiser's valuation conclusion misstated May 2000 Appraiser's valuation conclusion misstated in table.