IRS Reliance on Valuation Position Substantially Justified

Business Valuation UpdateVol. 9 No. 2
Legal and Court Case Update
February 2003
estate and gift taxation

Estate of Dailey v. Commissioner (II)
T.C. Memo 2002-301
December 9, 2002
Federal Court
United States Tax Court
Jeffrey A. Schumacher (for petitioners)


This case is a follow-up to the substantive issues addressed in Estate of Dailey v. Commissioner, T.C. Memo 2001-263 (U.S. Tax Ct. Oct. 3, 2001), which was abstracted in the December 2001 issue of the Business Valuation Update.

See Also

Estate of Dailey v. Commissioner (II)

At issue is whether respondent's position relating to the valuation issue was substantially justified, and whether costs relating to the FLP issue are reasonable.