Valuation of Closely-Held Stock for Federal Tax Purposes: Approach to an Objective Method

The present double-standard approach to the valuation problem discriminates against owners of closely-held stock, that is, corporate shares which have no public market. The disparity of treatment is traceable to the unfortunate fact that, whereas actual sales or bona fide bid and asked prices govern the valuation for federal tax purposes of listed stocks and of unlisted stocks which are dealt in through brokers or have a market, the criteria employed in valuing closely-held stock are predominantly subjective. This makes a paradise for experts but they seldom agree and few, if any, of their assumptions and conclusions are anything more than unverified, and not always wholly disinterested, hunches. As a consequence, disagreement between taxpayer and revenue agent is frequent and the process of resolving disagreement is long and costly and the event uncertain. In short, the whole merry-go-round of valuing closely-held stock is wasteful and unfair. This paper and the study it reports are addressed to the possibility of improving the situation by making a fresh approach to the valuation of closely-held stock