This letter written by attorney Richard L. Dees is critical of new proposed IRS regulations under Internal Revenue Code (IRC) Section 2704(b). The letter goes into detail making the argument that the new regulations to modify the rules on valuation discounts would be declared invalid if those regulations are modeled after what was proposed in the green book explanation of Obama’s 2013 revenue proposals. This lengthy and detailed letter does not simply stop with the technical arguments against the new proposed regulations validity. The letter also reminds its reader of the failed history and enormous costs of past efforts by the IRS to implement similar objectives.
See Richard L. Dees, Attorney Criticizes Possible Changes to Valuation Discount Rules, Tax Analysists, August 31, 2015.
Special thanks to Richard L. Dees (McDermott Will & Emery) for bringing this article to my attention.
