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Other Added - The Importance of an Independent Valuation
Risk Management News ll accuracy-related penalties apply to tax returns due, without regard to extensions, after December 31, 1989.Risk management is the act or practice of controlling risk. Most businesses re very interested in understanding the ways to control risk. This has created a secondary industry focused on mitigating risk and providing management information that allows business to gain In controversies with the IRS which concern valuation issues, it is not uncommon for the IRS to assess accuracy-related penalties. Impact 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 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 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 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 (1) the negligence 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 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 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 valuation cases, the Tax Court has consistently refused to allow these assessments when the tax payer has acted “reasonably” by engaging a valuation professional who has obtained proper training in valuation theory. Therefore, it is extremely important that the person performing your valuation not only be independent, but also qualified to perform such a valuation. If the person performing your valuation, whether or not they are a CPA, does not regularly perform valuations as part of their practice, for purposes above and beyond your engagement, chances are they are not qualified to perform the valuation as it relates to accuracy-related penalties.
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