The results of these approaches are reconciled and weighted giving consideration to the strengths or weaknesses of the inputs and approaches to value to form an opinion of value.
Our valuation analyses comply with USPAP (Uniform Standards of Professional Appraisal Practices) and, depending upon the situation, other applicable standards including Internal Revenue Ruling 59-60. Here is a list of common appraisal types:
Operating Companies
The value of an operating company is based on the expected future benefits which can include cash flow and/or capital appreciation. Minority interests in privately held companies are typically discounted for lack of control and lack of marketability.
Our experienced appraisal teams uses modern appraisal techniques to value operating companies in a manner that will withstand the scrutiny of the Internal Revenue Service or Tax Court. We use real word methodologies that exceed IRS guidelines to meet adequate disclosure requirements.
Family Limited Partnerships/LLCs
When valuing a minority interest in an entity that owns real estate, marketable securities or oil and gas assets, we use BV Best Practices (see article) to calculate Fair Market Value using the Income Approach and Market Approach. These were the approaches used in the Estate of Elsie Church to support the lack of control (“DLOC”) and lack of marketability (DLOM) of the FLP interest.
Many of our senior professionals listed below have testified in tax court and have been published in authoritative texts on these issues. Please contact one of them to have a more detailed conversation.
Promissory Notes
It is fairly common for gift and estate tax clients to have promissory notes in their estates. Frequently, a note between related parties originates at a below market interest rate based on published IRS Applicable Federal Rates. This and other factors result in the note being discounted.
Marshall & Stevens uses proven methodologies to value privately held promissory notes where the terms of the note are compared to the market to determine if the note is worth less than the outstanding balance (see attached article).