Private business appraisal must be based on information available at the required date of appraisal, according to Revenue Ruling 59-60. Business valuation experts generally consider only information that is “known or knowable” on the valuation date. But there are exceptions to this rule. In a recent case, Estate of Jung v. Commissioner, the U.S. Tax Court made an important distinction between subsequent events that affect fair market value and those that provide an indication of value. This brief article explains this distinction and under what circumstances business valuation experts may be able to use subsequent events in their analyses.
Estate of Jung v. Commissioner, 101 T.C. 312, 1993