IRS Challenges Family LLC as Indirect Gift, Including 58% Marketability Discount

Business Valuation UpdateVol. 15 No. 10
Legal and Court Case Update
October 2009

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6798 Real Estate Investment Trusts
531110 Lessors of Residential Buildings and Dwellings
federal taxation
Heckerman v. Commissioner
2009 WL 2240326 (W. D. Wash)
July 27, 2009
US
Federal Court
Washington
United States District Court
Coughenour

Summary

Court finds $2.5 million cash transfers to family limited company are indirect gifts, subject to gift tax for full value, excluding 58% marketability discounts.

See Also

Heckerman v. Commissioner

Full Text of Court Cases
July 27, 2009

Court finds $2.5 million cash transfers to family limited company are indirect gifts, subject to gift tax for full value, excluding 58% marketability discounts.