Presence of Independent Valuation One Factor in Determining Whether Note Transaction Was Bona Fide

Business Valuation Update BVLaw
Legal and Court Case Update
December 27, 2005

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estate and gift taxation
Estate of Winifred Hughes v. CIR
T.C. Memo. 2005-296
US
Federal Court
United States Tax Court
David S. Grossman, Julie L. Payne
Colvin

Summary

The U.S. Tax Court determined that the amount paid on a demand note after the death of the decedent was not deductible under sec. 2053 as a claim against the estate because the transaction was not bona fide nor completed at arm’s-length.

See Also

Estate of Winifred Hughes v. CIR

Full Text of Court Cases
December 27, 2005

The U.S. Tax Court determined that the amount paid on a demand note after the death of the decedent was not deductible under sec. 2053 as a claim against the estate because the transaction was not bona fide nor completed at arm’s-length. In reaching this ...