Thoughts and Insights by Michael Gregory

Audits and What’s New at the IRS

A C-clamp squeezing a wallet with dollar bills in it
June 27th, 2022

Is the IRS Job Aid on Reasonable Compensation still relevant?

The IRS valuers identified reasonable compensation as one of the top issues for audit. Differences of opinion by valuers in the private sector and IRS valuers could lead to conflict and disputes on examination, leading to Appeals, and potentially to litigation. This commentary defines reasonable compensation, introduces the IRS Job Aid and Appendix, provides links to some recent IRS papers related to reasonable compensation, introduces how various levels at the IRS look at the issue, provides links to relevant court cases and key factors for consideration from those court cases, and provides a source for contemporary commentary on this topic.

A mansion with many rooms and a big garage
August 24th, 2020

This is how to interact with an IRS Estate and Gift Tax Attorney on a valuation issue

It was my pleasure to be interviewed by Melissa Gragg, the Managing Partner at Bridge Valuation Partners, LLC, via her pod cast on this topic. For those not interested in listening to a nearly 90 minute podcast with lots of details, here is a much shorter seven minute version sound bites on LinkedIn. However, for those looking for a quick read on some of the key points this may help. We discussed over a dozen questions and additional follow up questions, but here are some of the key points.

Tax type papers, coffee cup and calculator on a destk
January 6th, 2020

Token Concessions and Counteroffers in Negotiations with the IRS on Business Valuations

When you think of negotiations, do you think about the IRS? With all of the negatives on TV about the big bad IRS it is important to realize they are people with a job to do, and they are indeed people. As with any organization there can be zealots that are over the top. Depending on your experiences you may have met one, and that person may have set your bias on the IRS. However, the vast majority of IRS examiners are reasonable people. if you are open to resolving issues with the IRS, here are two key elements to consider. Before proceeding, reflect and remember your ethical principles and values to be true to yourself. If what you want to do is do the right thing, do what it takes and have closure these ideas can help you with the IRS. Let’s look at token concessions first.

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