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NOTES 475 Tax Lawyer, Vol. 56, No. 2 NOTE THE APPLICABILITY OF A MARKET APPROACH VALUATION ANALYSIS THAT EMPLOYS ONLY A SINGLE COMPARABLE: HECK V. COMMISSIONER In Estate of Heck v. Commissioner1, the Tax Court refused to adopt the Service’s application of the market approach2 as part of a closely held company’s valuatiio where the expert relied on only one comparable company.3 Instead, the court relied exclusively on the discounted cash flows (DCF) method4 to arrive at the company’s valuation and...

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