Having Lost the War on Family LLC, IRS Loses the Battle on the Discounts

Business Valuation UpdateVol. 16 No. 7
Legal and Court Case Update
July 2010
6733 Trusts, Except Educational, Religious, and Charitable
525920 Trusts, Estates, and Agency Accounts
federal taxation

Pierre v. Commissioner (II)
2010 WL 1945779 (U.S. Tax Ct.)
May 13, 2010
US
Federal Court
Federal
United States Tax Court
Kathryn Keneally
James F. Shuey and Daniel Kerrigan (taxpayer)
Kroupa

Summary

Tax Court applies step transaction doctrine to formation and funding of family LLC, and then applies taxpayer’s discounts for lack of control and marketability, in absence of IRS evidence regarding the same.

See Also

Pierre v. Commissioner (II)

Tax Court applies step transaction doctrine to formation and funding of family LLC, and then applies taxpayer’s discounts for lack of control and marketability, in absence of IRS evidence regarding the same.