Janda v. Commissioner

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Full Text of Court Cases
February 2, 2001

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6712 Offices of Bank Holding Companies
551111 Offices of Bank Holding Companies
estate and gift taxation
net asset value, restricted stock study, discount for lack of marketability (DLOM), fair market value (FMV), gift tax, growth rate, holding period, quantitative marketability discount model (QMDM), holding company
Janda v. Commissioner
T.C. Memo 2001-24, 2001 Tax Ct. Memo LEXIS 34
US
Federal Court
United States Tax Court
Grant Thornton firm (for taxpayer on return); Gary L. Wahlgren (for taxpayer); Philip J.Schneider (for IRS)
Vasquez

Summary

In November 1992, the Petitioners gifted shares of St. Edward Management Company (the "Company") common stock to their children. Each gift represented approximately 5.3% of the outstanding shares of common stock. St. Edward Management Co. owned 94.6% of the common stock of the Bank of St. Edward (the Bank), a bank located in a small agricultural community in Nebraska.
Janda v. Commissioner
PDF, Size: 27 KB

See Also

Tax Court Considers QMDM and Restricted Stock Studies in Determining Discount for Lack of Marketability

Legal and Court Case Update
March 2001

In November 1992, the Petitioners gifted shares of St. Edward Management Co. (the "Company") common stock to their children.