In the past decade, taxpayers grew accustomed to increasing valuation discounts thanks to a string of victories over the Internal Revenue Service. But that trend appeared to end in early 2003. Now the IRS, through the Tax Court, has delivered three body blows to the taxpayer in a series of 2003 cases: McCord,1Lappo2 and Peracchio.3 This triple play of cases indicates the IRS will battle tooth and nail for lower discounts — and will achieve some degree of success. But the underlying facts of ...

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