What is Revenue Ruling 59-60?
Revenue Ruling 59-60, promulgated in 1959, addressed a desire by the Internal Revenue Service to set forth fundamental issues appraisers should consider when valuing a privately-owned business for estate and gift tax purposes. Rev. Rul. 59-60 is not a “how to”; rather it is an excellent discussion of eight broad factors the appraiser should take into account to reach a value conclusion. Rev. Rul. 59-60, 1959-1 CB 237—IRC Sec. 2031 Sec. 2031—DEFINITION OF GROSS ESTATE 26 CFR 20.2031-2: Valuation of stocks and bonds. (Also Section 2512.) (Also Part II, Sections 811(k), 1005, Regulations 105, Section 81.10.) Headnote: In valuing the stock of closely held corporations, or the stock of corporations where market quotations are not available, all other available financial data, as well as all relevant factors affecting the fair market value must be considered for estate tax and gift tax purposes. No general formula may be given that is applicable to the many different valuation situations ari
