Chrem v. Commissioner

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September 26, 2018

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3651 Household Audio and Video Equipment
334310 Audio and Video Equipment Manufacturing
federal taxation
appraisal standards, charitable contribution, discount for lack of marketability (DLOM), fair market value (FMV), going concern, minority discount, employee stock ownership plan (ESOP), reasonable cause
Chrem v. Commissioner
2018 Tax Ct. Memo LEXIS 164
US
Federal Court
Federal
United States Tax Court
Empire Consultants LLC (petitioners); unknown (respondent)
Lauber

Summary

Court finds using ESOP appraisal to show “qualified appraisal” is a long shot to meet charitable contribution verification requirements because appraisal did not consider tax consequences or value shares individual petitioners donated, but petitioners may have reasonable cause defense.
Chrem v. Commissioner
PDF, Size: 112 KB

See Also

Can ESOP Appraisal Satisfy Charitable Contribution Reporting Requirement?

Court Case Digests
September 26, 2018

Court finds using ESOP appraisal to show “qualified appraisal” is a long shot to meet charitable contribution verification requirements because appraisal did not consider tax consequences or value shares individual petitioners donated, but petitioners may have reasonable cause defense.