When Superman was trapped in “Bizarro World,” he found everything was the opposite of its earthly counterpart. Or, as Jerry Seinfeld observed, for an inhabitant of Bizarro World, “Up is down, down is up, he says ‘hello’ when he leaves, ‘goodbye’ when he arrives.”1 Several long-standing valuation issues were subject to a type of “up is down” treatment in 2011. Tax-affecting S Corporation Earnings The Tax Court continues to say “no” to tax-affecting the value of S corporation earnings (that ...

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