[Exhibitman]

I am not a tax attorney, I just research this stuff for my own planning and information.

All of these tax questions are both specialized and personal: do NOT take the word of some stranger on a chat board, see your own tax planner. What someone says here might not even apply to you.

Now, when it comes to fighting over your positions, that too is idiosyncratic. I can stand my ground against the tax people more than most because my cost of litigation is zero. If I had to hire an attorney I'd be much more wary of getting into a fight because the cost of fighting makes a winner into a loser.

As far as valuation goes, there is no explicit requirement that I have ever heard of for an appraisal by a specific form of appraiser, except in the charitable deductions area. Appraisals are just speculative opinions anyway. When my parents passed away, I found a series of insurance appraisals they got for various things and they were nowhere near market valuation. They were way off because they were a means of setting up a bigger insurance claim not of establishing a true market value. The tax opinions I've read on valuation disputes all basically amount to what we call a "whore fight": the IRS puts up one expert to say X, the taxpayer puts up another to say Y, and the court decides who has the better liar.

One further thing to consider: there is no need to liquidate right away. Unless there is a reason to quick sell, you can take your time and do it right.