Estate of True v. Commissioner

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July 6, 2001

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2911 Petroleum Refining
324110 Petroleum Refineries
estate and gift taxation
buy-sell agreement, pre-IPO study, restricted stock study, estate tax, fair market value (FMV), gift tax, net asset value approach (NAV), swing vote
Estate of True v. Commissioner
T.C. Memo 2001-167, 2001 Tax Ct. Memo LEXIS 199
US
Federal Court
United States Tax Court
John H. Lax, ASA, CMA (for estate)<br>Curtis R. Kimball, ASA, CFA (for estate)<br>John B. Gustavson, AIMA (for IRS)
Beghe
Estate of True v. Commissioner
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Buy-Sell Agreements Fail Lauder II Test and Are Considered Testamentary Devices

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This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.

Buy-Sell Agreements Are Testamentary Devices

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This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.

Buy-Sell Agreements Do Not Control for Estate Tax Purposes

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The Tax Court considered whether buy-sell agreements controlled the value of the business interests the decedent held for estate and gift tax purposes.