Over the years at the Internal Revenue Service, Michael A. Perlmutter has selected for audit and reviewed thousands of appraisals. Perlmutter has gathered the knowledge and experience to identify appraisals that are credible and reliable and those possessing "red flags" with significant weaknesses and faults.
It is important to follow valuation industry standards of report writing. Adequate analysis is key, as is providing appropriate data to support the appraiser assumptions and conclusions. Just presenting studies and court cases is not enough.
One area Perlmutter specializes in is determining the fair market value of partial interests in business entities and fractional interests in real property. Valuation discounts are applied as appropriate. All valuation conclusions are supported by analysis and data.
Bottom-line is Perlmutter knows how to spot "red flags", those errors, omissions and inconsistencies that lessen the credibility of the appraisal. Eliminating these damaging "red flags" may decrease the chances of an IRS audit.
Intellectual property valuation
This is a highly specialized field that is receiving increased scrutiny by the IRS. Perlmutter has reviewed and actively helped prepare may intellectual property valuation appraisals, which include name and likeness rights (Right of Publicity) and revenue streams from copyrighted music and film royalties.
Perlmutter has written Intellectual Property valuation training materials for IRS new hire attorneys, he has made presentations on a national scale to IRS attorneys, has presented the IRS position at Appeals conferences and had been actively involved in many aspects in a significant tax court case that involved intellectual property valuation, business valuation and discounting of partial interests.
Perlmutter has reviewed many poorly written and poorly supported IP appraisals. He can spot the weaknesses and "red flags". So can the IRS. And Perlmutter knows what constitutes a well written, defensible IP appraisal. Perlmutter can guide you through this process.
As an IRS Revenue Agent and as an Estate Tax Attorney, Perlmutter has experience with individual and corporate tax law issues as well as tax issues in the context of Estate and Gift.
Valuation Appraisal Review and Consultation
Partial Interest discounts in determining fair market value of business interests
Fractional interest discounts in determining fair market value of real property interests
Intellectual property valuation consulting and appraisal, specializing in name and likeness rights and copyright royalty stream valuation from music and/or film.
Tax law consulting, specializing in estate & gift tax issues
Taxpayer Representation assistance in IRS audits