Over the 12 years since the Treharne Model was first published, a number of other S corporation valuation models have been published. Each model has been subjected to peer review.

Contrary to the recommendations of the published models, a number of experts have testified in Tax Court and other venues regarding the inappropriateness of recognizing the income tax liability associated with S corporation income. To my knowledge, a peer reviewed article supporting their testimony has never been published. If anyone has knowledge of such articles, I'd greatly appreciate their citations.

Alternately, if a reader advocates not adjusting economic income to reflect the satisfaction of income tax liabilities associated with S corporation income, I'd like to encourage them to submit an article on the topic.

You do not currently have access to this content.