The IRS has dedicated Valuation Analysts assigned specifically to determine if taxpayers are avoiding paying taxes by manipulating the reporting of compensation expense. Entities with elevated risk of IRS concern include family businesses, closely held businesses, subchapter S corporations, and foreign corporations. Transactions that may lead to similar concerns include acquisitions, divestitures, adjustments to prior year compensation, and different types of loans. When the IRS raises reasonable compensation concerns and challenges the taxpayer, the burden of proof falls on the taxpayer to support and justify the compensation expense.