Estate of Koons v. Commissioner (Koons II)

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April 27, 2017

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5962 Automatic Merchandising Machine Operator
454210 Vending Machine Operators
estate and gift taxation
expert testimony, regression analysis, discount for lack of marketability (DLOM), estate tax, fair market value (FMV), discount for lack of control (DLOC), administrative expenses, estate and trusts, generation-skipping transfer tax
Estate of Koons v. Commissioner (Koons II)
2017 U.S. App. LEXIS 7415
US
Federal Court
11th Circuit
United States Court of Appeals
Mukesh Bajaj (petitioners/estate and revocable trust); Francis X. Burns (respondent/IRS)
Reeves

Summary

Affirming FMV conclusion, appeals court says Tax Court did not err in focusing less on details of methodology parties’ appraisers used than on larger issue of whether hypothetical seller would be able to force distribution of majority of LLC’s assets.
Estate of Koons v. Commissioner (Koons II)
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Eleventh Circuit Affirms Tax Court’s Valuation of Trust’s Interest in LLC

Court Case Digests
April 27, 2017

Affirming FMV conclusion, appeals court says Tax Court did not err in focusing less on details of methodology parties’ appraisers used than on larger issue of whether hypothetical seller would be able to force distribution of majority of LLC’s assets.