Summary
Tax Court adopts the taxpayer’s dollar-for-dollar discount for embedded capital gains tax liability based on 2nd Circuit precedent and its own present-value analysis but specifically declines to adopt the per se rule of the 5th and 11th Circuits.
See Also
Estate of Jensen v. Commissioner
Tax Court adopts the taxpayer’s dollar-for-dollar discount for embedded capital gains tax liability based on 2nd Circuit precedent and its own present-value analysis, but specifically declines to adopt the per se rule of the 5th and 11th Circuits.