Editor's note: The Kress case has received a great deal of attention
on a number of valuation front, most notably that both the taxpayer and
the government tax affected the earnings of the subject S corp. This letter
is a response to comments made by an IRS analyst that are in the accompanying
sidebar. Please note that the author of this letter is only providing
a summary, and is this is not intended to be a detailed valuation method.
To read the letter in full please