What’s Up with Revenue Ruling 59-60?

February 1, 2012

Revenue Ruling 59-60 is the primary ruling providing guidance for the valuation of closely held common equity interests. When issued in 1959, the ruling specifically referred to valuing “… the stock of closely held corporations where market quotations are not available.”

In 1968 the following paragraph from Revenue Ruling 68-609 expanded the scope of Revenue Ruling 59-60: “The general approach, methods, and factors, outlined in Revenue Ruling 59-60, as modified, are equally applicable to the valuation of corporate stocks for income and other tax purposes as well as for estate and gift tax purposes. They also apply to problems involving the determination of the fair market value of business interests of any type, including partnerships and proprietorships, and of intangible assets for all tax purposes.”

It is expected in the valuation community that the original text of Rev. Rul. 59-60 will be revised by the Service in the near future, though few expect major changes.

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