摘要：Valuation issues have long posed challenges for the U.S. federal tax system. This is not just
because of questions about what technique will most accurately value particular types of property.
A key problem for tax administration is that taxpayers have a financial incentive to claim erroneous, self-serving valuations. This Essay analyzes tax valuation through this tax compliance
lens. In so doing, it highlights the importance that third parties to the taxpayer-government
relationship act at arm’s length from the taxpayer. It also explains why penalties are insufficient
to deter erroneous self-reported valuations. The Essay also draws on the tax compliance perspective to make some preliminary observations about valuation methodologies.
