Courtney Sparks White (J.D. 2009, Capital) has published Comment, S Corporations: A Taxing Analysis of Proper Valuation, 37 Cap. U. L. Rev. 1117 (2009). Here is part of the Introduction:

This comment will focus on the appropriate way to account for taxes in valuing S corporations. The primary issue is whether or not to tax affect S corporations, which are pass-through entities, for valuation purposes. Once this is answered in the affirmative, the next issue is what the appropriate tax affect should be. There is a lack of uniformity among jurisdictions regarding these issues, but recent cases have shed some light on (1) applying a tax affect to S corporations and (2) the proper tax affect. This Comment argues that application of a tax affect to S corporations is appropriate for valuation purposes. A discussion of the differences between S corporations and C corporations is necessary to start the analysis, followed by a discussion of business valuation and its history and applicable approaches and methods. This comment focuses on four basic areas of law where valuation issues arise, including estate, gift, divorce, and shareholder disputes.

This comment then analyzes cases that have touched on this issue and the progress courts have made toward an appropriate analysis. Finally, this comment concludes with an appropriate analysis to apply in S corporation valuations to deal with tax issues.