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IRS Valuation Examinations - Michael A. Perlmutter

Federal disclosure rules prohibit naming specific taxpayers. 


During Mr. Perlmutter's 27 year career at the Internal Revenue Service as a Revenue Agent and Estate Tax Attorney, Mr. Perlmutter had the opportunity to review thousands of valuation appraisals in addition to the dozens he has reviewed in private practice.  Mr. Perlmutter focused on valuation related issues of some of the largest and highest profile estates. 


Mr. Perlmutter made presentations at IRS Appeals conferences and assisted IRS chief counsel and the IRS valuation team in a significant tax court case.


The following are some of the asset types he has reviewed:


Intellectual Property Assets

  • Name and Likeness Rights

  • Music Copyrights

  • Film copyrights

  • Trademarks

  • Patents

Business Assets

  • 100% interest in operating and passive entities (C-Corporation, S-Corporation, Partnerships, LLC)

  • Partial interests in operating and passive entities (discounts)

Real Property Assets

  • 100% interest in Commercial or residential property

  • Fractional Interests in commercial and residential property (discounts)

Other Assets

  • Promissory Notes

  • Personal Property

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