In Demutualization, IPO Share Price Guides Cost Basis Determination

Business Valuation UpdateVol. 19 No. 6
Legal and Court Case Update
June 2013
6311 Life Insurance
524113 Direct Life Insurance Carriers
federal taxation

Dorrance v. U.S.
2013 U.S. Dist. LEXIS 37745
March 19, 2013
US
Federal Court
Arizona
United States District Court
Unkown
Snow

Summary

In insurance demutualization, federal court declines to apply “open transaction doctrine” or adopt IRS’s zero cost basis approach; it finds the IPO price of the shares the taxpayers received under demutualization was “the first valuation of what Plaintiff ...

See Also

Dorrance v. U.S.

In insurance demutualization, federal court declines to apply “open transaction doctrine” or adopt IRS’s zero cost basis approach; it finds the IPO price of the shares the taxpayers received under demutualization was “the first valuation of what Plaintiff ...