5th Circuit Upholds Tax Court’s Characterization of Interest and Discount Rulings

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Court Case Digests
March 31, 2020

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6282 Investment Advice
523920 Portfolio Management
estate and gift taxation
discount for lack of control (DLOC), expert testimony, discount for lack of marketability (DLOM), estate tax, fair market value (FMV), partnership agreement, limited partnership, mandelbaum factors
Estate of Streightoff v. Commissioner (II)
2020 U.S. App. LEXIS 10070
US
Federal Court
5th Circuit
United States Court of Appeals
Juliana Vicelja (IRS); Oliver Warnke, Alan Harp (estate)
Stewart

Summary

5th Circuit affirms Tax Court’s ruling that decedent’s transferred interest is limited partner, not an assignee, interest; appeals court says estate’s related challenge to Tax Court’s valuation reflects disagreement with characterization of interest, not value computation; valuation holds up.

See Also

Estate of Streightoff v. Commissioner (II)

Full Text of Court Cases
March 31, 2020

5th Circuit affirms Tax Court’s ruling that decedent’s transferred interest is limited partner, not an assignee, interest; appeals court says estate’s related challenge to Tax Court’s valuation reflects disagreement with characterization of interest, not value computation; valuation holds up.