Forcing the risk on IRS is exactly the point. The idea is to force them to value things in a (more) rational way. Today, they don't have to. Their incentive is

Forcing the risk on IRS is exactly the point. The idea is to force them to value things in a (more) rational way. Today, they don't have to. Their incentive is exactly the opposite: overvalue things to get more tax out of it. I think we can all agree the best thing is to take away ability to tax phantom money from IRS. Next best thing is to setup the rules so that IRS is on the hook if they overvalue phantom money.