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SKMB P.A. - Tremendous Success

IRS allows a 35% discount on an amended business valuation of a Corporation with one stockholder

- Estate Executor -
The IRS Wrote My Client a Check for $2,689,269
It started with a valuation by the IRS that was way higher than it should be.

My client was an estate that had filed an Estate Tax Return and had paid substantial Estate Taxes, This estate included two companies owned 100% by a single stockholder. Both had been taxed based on valuations performed by a nationally recognized valution firm. One was at $17.8M, the other at $7.7M.

The larger company was valued with no discount, despite being a holding company for several diverse companies, which would be very difficult to sell. The smaller had a small valuation discount, but was dependent on only one client for almost all its revenue.

Keep reading below for what I did. It was worth millions to my client.

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At SKMB, we are proactive communicators and dedicated collaborators. Accounting is far more than handling taxes. We work closely with our clients, establishing a comprehensive strategy that will maximize efficiency and minimize waste year-round.

Ed Bortnick


Edward A. Bortnick, CPA, CVA, CFD, MAFF, CFF
I've been a Principal since 1977. I focus on litigation services, specializing in valuations, bankruptcy, and divorce. Call me at 301.468.7700 or email me at
I Found Precedents That Saved My Client Millions
Research showed this wasn't the first time the IRS valuated high and the courts said no.

My research discovered cases where the courts awarded substantial valuation discounts for corporations with one stockholder. The IRS allowed the larger company a lack of marketability and a mix of assets discount totaling a 35% discount. The smaller company had one major customer, and ther for was worth an additional 11% discount due to risk.

I filed amended returns with the IRS. After getting through appeals and the joint committee, the return was approved and my client received a check for $2,689,269.

This wasn't even my first such experience. A previous estate client received a refund of $1.6 million for a wholly owned ownership position based on my amended valuations. Once could be a fluke, but that's two big checks back for my clients.

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If you are not up to date on court cases containing valuation discounts we would be happy to review any business valuations contained in the 706 or other matters such as marital or stockholder disputes.

Don't Leave Millions on the Table
We work with estate attorneys to get documented, justified valuations that save clients money, sometimes large sums, in taxes.
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