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  • Article Check - The Importance of an Independent Valuation

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    nce penalty
    (2) the substantial understatement of income tax penalty
    (3) the substantial valuation overstatement penalty
    (4) the substantial estate o
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    Not only is an independent valuation a good idea when getting involved in a transaction, it is also a statutory requirement in many circumstances that involve Employee Stock Ownership Plans, Estate/Gift Taxes, Charitable Contributions or, most recently, the granting of Stock Options. And, in most circumstances, a solid independent valuation can be an insurance policy against tax assessments and accuracy-related penalties.

    Background – The Omnibus Budget Reconciliation Act (OBRA) consolidated into one Internal Revenue Code section (IRC §6662) several different accuracy-related taxation penalties:

    (1) the negligence penalty
    (2) the substantial understatement of income tax penalty
    (3) the substantial valuation overstatement penalty
    (4) the substantial estate or

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    yee Stock Ownership Plans, Estate/Gift Taxes, Charitable Contributions or, most recently, the granting of Stock Options. And, in most circumstances, a solid independent valuation can be an insurance policy against tax assessments and accuracy-related penalties.

    Background – The Omnibus Budget Reconciliation Act (OBRA) consolidated into one Internal Revenue Code section (IRC §6662) several different accuracy-related taxation penalties:

    (1) the negligence penalty
    (2) the substantial understatement of income tax penalty
    (3) the substantial valuation overstatement penalty
    (4) the substantial estate o

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    During a time when the commercial real estate market is competitive, agents often hire designers to create the right atmosphere. While designers often make a residential home seem more livable, their goal when dealing with commercial properties is to make the space seem
    ndent valuation can be an insurance policy against tax assessments and accuracy-related penalties.

    Background – The Omnibus Budget Reconciliation Act (OBRA) consolidated into one Internal Revenue Code section (IRC §6662) several different accuracy-related taxation penalties:

    (1) the negligence penalty
    (2) the substantial understatement of income tax penalty
    (3) the substantial valuation overstatement penalty
    (4) the substantial estate o

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    conciliation Act (OBRA) consolidated into one Internal Revenue Code section (IRC §6662) several different accuracy-related taxation penalties:

    (1) the negligence penalty
    (2) the substantial understatement of income tax penalty
    (3) the substantial valuation overstatement penalty
    (4) the substantial estate o

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    Several companies specialize in providing packaging services that are sourced by manufacturers to deliver well packaged products to their consumers. The existence and usage of highly sophisticated packaging equipment for different kinds of products has made good quality
    nce penalty
    (2) the substantial understatement of income tax penalty
    (3) the substantial valuation overstatement penalty
    (4) the substantial estate or gift tax valuation understatement penalty
    (5) the substantial overstatement of pension liabilities penalty

    The accuracy-related penalty is applied to the portion of any underpayment of tax that is attributable to one or more of the above five issues. All accuracy-related penalties apply to tax returns due, without regard to extensions, after December 31, 1989.

    In controversies with the IRS which concern valuation issues, it is not uncommon for the IRS to assess accuracy-related penalties.

    Impact of an Independent Valuation – Even though the IRS attempts to assess accuracy-related penalties in val

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