“Read the Jones case,” an IRS official said when asked about the position the IRS is taking on tax affecting pass-through entities. In that case (Estate of Aaron Jones v. Commissioner, T.C. Memo. 2019-1011), the U.S. Tax Court, ruling on an Oregon gift tax dispute, accepted the taxpayers’ tax-affected valuations of pass-through entities without overturning Gross. The Tax Court’s decision was an all-out win for the taxpayers and came on the heels of the Kress case, in which a federal district court adopted the taxpayers’ tax-affected valuations of an S corp. During an upcoming four-hour workshop, former IRS manager Michael Gregory (Michael Gregory Consulting) will discuss the Jones case as well as other matters in How Recent Challenges With the IRS Impact Your Valuation, on March 31.
A digest of Estate of Aaron Jones v. Commissioner, T.C. Memo. 2019-101, as well as the court’s decision, is available to BVLaw subscribers.
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