Tax Disputes

Global Economics Group experts have decades of experience in the valuation of privately-held companies and other financial instruments within the context of estate, gift, and income tax reporting and disputes.

In addition, we have consulted on excessive compensation claims, transfer pricing matters, and other tax-related valuation disputes. Our extensive valuation background includes assets such as closely-held company stock and member interests, privately-held promissory notes and other debt instruments, and split-dollar life insurance receivables. 

Our experts, which include accredited appraisers and CPAs, have provided testimony in federal district courts and U.S. Tax Court. We have also assisted clients in administrative proceedings, including fast-track mediations and the Internal Revenue Service Appeals process. 

Clients include individual and corporate taxpayers, the U.S. Department of Justice, and the IRS. 

Sample of Engagements

+  Assisted taxpayer with valuation of intrafamily promissory notes for estate tax filing purposes 

+  Retained by the IRS to value split-dollar receivables and split-dollar notes (served as expert in Estate of Morrissette v. Comm’r.) 

+  Appraised privately-held glass manufacturing company on behalf of IRS (dispute settled by parties prior to trial) 

+  Hired by taxpayer to support executive compensation in mediation with IRS (successful resolution prior to litigation)  

+  Consulted with taxpayer’s counsel to resolve a split-dollar insurance valuation dispute with the IRS (we were contacted independently by both parties to serve as expert) 

+  Participated in fast-track mediation on behalf of the estate of a children’s book author that resulted in the settlement of a tax dispute within one day