Tax Court Split 9 to 6 on Preserving Family LLC for Gift vs. Income Tax Purposes

Business Valuation UpdateVol. 15 No. 11
Legal and Court Case Update
November 2009

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6733 Trusts, Except Educational, Religious, and Charitable
federal taxation
Pierre v. Commissioner (I)
2009 WL 2591652 (U.S. Tax Ct.)
August 24, 2009
US
Federal Court
Federal
United States Tax Court
Kathryn Keneally
James F. Shuey (taxpayer)
Wells

Summary

In a 9-to-6 split decision, U.S. Tax Court decides that “check-the-box” regulations, which disregard the entity form of a single-member LLC for federal income tax purposes, do not apply to assessments of federal gift taxes.

See Also

Pierre v. Commissioner (I)

Full Text of Court Cases
August 24, 2009

In a 9-to-6 split decision, U.S. Tax Court decides that “check-the-box” regulations, which disregard the entity form of a single-member LLC for federal income tax purposes, do not apply to assessments of federal gift taxes.