IRS Contends License Payments 'a sham'

Business Valuation UpdateVol. 2 No. 10
Legal and Court Case Update
October 1996

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5961 Catalog and Mail-Order Houses
454110 Electronic Shopping and Mail-Order Houses
estate and gift taxation
discounted cash flow (DCF), arm's length
Speer v. Commissioner
T.C. Memo 1996-323, 1996 Tax Ct. Memo LEXIS 340
July 16, 1996
US
Federal Court
United States Tax Court
Robert F. Reilly (for taxpayer)<br>Douglas F. Benn (for IRS)
Ruwe

Summary

The ultimate issue in this case is whether taxable gifts or constructive dividend income were received by the son of the controlling shareholder of Home Shopping Network (HSN), through Pione ...

See Also

Speer v. Commissioner

Full Text of Court Cases
July 16, 1996

At issue is the valuation of a software licensing company for federal income and gift tax purposes.