Since 1999, the Tax Court, Internal Revenue Service and the business valuation profession have been at odds regarding the proper means to value pass-through entities (PTEs) such as subchapter S corporations (S corps), limited liability companies and partnerships. In multiple Tax Court decisions dating back to 1999, the primary controversy has revolved around the question of whether PTEs should be valued on a C corporation (C corp) equivalent basis or some other basis that reflects the tax
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