Keeping Gross Alive, Nimble Tax Court Accepts PTE Tax Affecting

BVLaw
Court Case Digests
August 19, 2019

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2421 Sawmills and Planing Mills, General
321113 Sawmills
estate and gift taxation
expert testimony, income approach, net asset value, tax affecting, discounted cash flow (DCF), fair market value (FMV), s corporation, pass-through entity
Estate of Aaron Jones v. Commissioner
T.C. Memo. 2019-101
US
Federal Court
Federal
United States Tax Court
Richard Reilly (petitioner/estate); Philip Schwab, John Ashbrook (respondent/IRS)
Pugh

Summary

In gift tax dispute, Tax Court adopts estate expert’s valuation of two related PTEs, including expert’s tax affecting; court distinguishes Gross and later cases; issue is not whether to tax affect but how; estate expert’s tax affecting was “more accurate than [IRS’] blunt zero-rate approach.”

See Also

Estate of Aaron Jones v. Commissioner

Full Text of Court Cases
August 19, 2019

In gift tax dispute, Tax Court adopts estate expert’s valuation of two related PTEs, including expert’s tax affecting; court distinguishes Gross and later cases; issue is not whether to tax affect but how; estate expert’s tax affecting was “more accurate than [IRS’] blunt zero-rate approach.”

This article also appears in:
Business Valuation UpdateVol. 25 No. 10