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The IRS commissioner failed to perform a legitimate asset valuation analysis throughout the audit, discovery and litigation of this case, and the Tax Court erred in failing to hold the commissioner to his burden of proof and in selecting an incorrect method to value the assets of the taxpayer's entities and made clearly erroneous factual findings in applying this valuation method.
July 31, 2006 at 12:00 AM
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The original version of this story was published on Texas Lawyer
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