When reading the U.S. Tax Court decision in Gallagher v. Commissioner,1 I was reminded of the 1993 comedy “Groundhog Day.” As you may recall, Phil Connors (played by Bill Murray) is a TV weatherman who finds himself repeating the same unpleasant day over and over again when covering the annual Groundhog Day event in Punxsutawney, Pa. Gallagher is similar to the movie in that we seem to be stuck in a perpetual time loop with respect to the valuation of equity interests ...

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