Connelly case kicks off Heckerling conference

BVWireIssue #256-3
January 24, 2024

estate and gift taxation
estate and gift tax, estate & gift, conference, insurance

At the Heckerling Institute on Estate Planning in Orlando, Fla., earlier this month, the first session was a panel on key court cases of 2023, and “valuation was top of mind for many federal courts,” according to coverage in Connelly v. United States was front and center—this is the case the U.S. Supreme Court will hear to resolve a circuit split. The question to be resolved is: How should corporate-owned life insurance (COLI) designed to fund the redemption of a deceased shareholder’s stock impact the fair market value of the subject company and the value of the decedent’s gross estate? A complete analysis of the valuation issues in the case by Roger Grabowski (Kroll) is in the January issue of Business Valuation Update.

The panel at Heckerling also discussed the Cecil case on tax affecting (a case that should be very familiar to valuation experts) and Schlapfer, a Tax Court case that was a “huge victory” for the taxpayer over the adequate disclosure issue.

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