Fractional Interest in Estate Tax Turns on Type, Timing of Gift

Business Valuation UpdateVol. 17 No. 4
Legal and Court Case Update
April 2011

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federal taxation
Estate of Adler v. Commissioner of Internal Revenue
T.C. Memo. 2-11-28, 2011 WL 300144 (U.S. Tax Court)
January 31, 2011
US
Federal Court
Federal
United States Tax Court
unnamed
Morrison

Summary

Whether gifts of property should be valued as a whole or as separate fractional interests, with appropriate discounts, depends on when the interests are separated, during the decedent’s lifetime or at death.

See Also

Estate of Adler v. Commissioner of Internal Revenue

Full Text of Court Cases
January 31, 2011

Whether gifts of property should be valued as a whole or as separate fractional interests, with appropriate discounts, depends on when the interests are separated, during the decedent’s lifetime or at death.