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Estate of F. Wallace Langer et al. v. Commissioner

Estate of F. Wallace Langer et al. v. Commissioner; T.C. Memo. 2006-232; No. 11116-04 (30 Oct. 2006) ESTATE OF F. WALLACE LANGER, DECEASED, CLARENCE D. LANGER, JR., EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent UNITED STATES TAX COURT Filed October 30, 2006 John H. Draneas, for petitioner. Wesley F. McNamara, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HAINES, Judge: Respondent determined a Federal estate tax deficiency of $949,686 against the Estate of ...

5th Circuit Reverses McCord, Confirming Original Valuation of Marketability Discounts

5th circuit overturns McCord v. Comm’r (Tax Court, 2003) and confirms calculation of marketability discounts in complex gift tax case.

Dallas v. Commissioner

In a post-Gross decision, the Tax Court considers tax-affecting S Corp earnings and also discounts for lack of marketability and control.

Kohler: Textbook Valuation of Large Closely Held Corporation Leads to Total Victory for Taxpayer

A “textbook case” on how to value a large, closely held corporation, complete with discussion of dividend method and appropriate discounts.

‘Classic’ FLP Case by Judge Laro Finds No §2036 Estate Tax Exception

Classic case where Tax Court (Judge Laro) finds no §2036 estate tax exclusion for family limited partnership (FLP).

McCord v. Commissioner (II)

Fifth circuit overturns McCord v. Comm’r (Tax Court, 2003), and confirms calculation of marketability discounts in complex gift tax case.

Conrad Janis v. CIR (Janis II)

The U.S. Court of Appeals for the Ninth Circuit affirmed the Tax Court’s determination of the fair market value of an inherited art collection for partnership basis purposes, inclusive of a blockage discount. The court also analyzed the duty of consistenc ...

Blockage Discount Reconsidered

The U.S. Court of Appeals for the 9th Circuit affirmed the Tax Court’s determination of the fair market value of an inherited art collection for partnership basis purposes, inclusive of a blockage discount.

Wechsler & Co. v. Commissioner of Internal Revenue

Court rejects reasonable compensation analysis for lack of reasonable comparables to broker/dealer in convertible securities ...

First Time Buy-Sell Agreement Meets Tax Court Requirements for Gift/Estate Valuation

Buy-sell agreement upheld for purposes of establishing estate tax value.

Lottery Winner Attempts Second Win on Discounted Present Value of Annuity

Court assesses whether fair market value of nonmarketable annuity varies from present value of IRC annuity tables.

‘Friends and Family’ Gifts of Private Stock Support 50% DLOM

Court considers whether family gifts of closely held stock were “arm's length,” sufficient to support 50% discounts.

Herbert V. Kohler v. CIR

The U.S. Tax Court determined the fair market value of a minority interest in a well-known manufacturer of kitchen and bath fixtures and accessories. The court rejected the IRS’s valuation as incredible because the expert carried no business valuation cre ...

Kohler et al. v. Commissioner of Internal Revenue

A “textbook case” on how to value a large, closely-held corporation, complete with discussion of dividend method and appropriate discounts. A total victory for the taxpayer.

Latest Court Looks at DLOM: Assumptions Are Everything

In gift/estate case, court considers discounts for lack of marketability and control for LLPs/LLCs and rejects flawed applications of QMDM and Mergerstat data.

‘Lockstep’ Transfers of Minority Interests Submerge—But Do Not Sink—Discounts

Contemporaneous, aggregate transfer of minority interests reduce (but don’t reverse) minority discounts.

Estate of Lillie Rosen v. CIR

The U.S. Tax Court applied a multifactor analysis to determine whether the objective facts indicated whether an FLP had a legitimate and substantial nontax purpose such that sec. 2036 did not apply to recapture the value of assets transferred to a family ...

Huber v. Commissioner

Court considers whether family gifts of closely-held stock were “arms length,” sufficient to support 50% discounts ...

Estate of Pearl I. Amlie v. Commissioner

Buy-sell agreement upheld for purposes of establishing estate tax value ...

Estate of Douglas L. Manship v. United States of America

The U.S. District Court for the Eastern District of Louisiana determined that document produced by an appraiser, who considered them in performing the valuations that were attached to the estate tax return, and who was listed an a testifying expert pursua ...

Court Finds Attorney-Client Privilege Waived in Connection With Documents Supplied to Estate’s Valuation Expert

The U.S. District Court for the Eastern District of Louisiana determined that documents produced by an appraiser, who considered them in performing the valuations that were attached to the estate tax return, were not covered by the work product or attorney-client privilege.

Koblick v. Internal Revenue Service

Contemporaneous, aggregate transfer of minority interests reduce (but don’t reverse) minority discounts.

Keeping It Simple Rules the Day on Partnership Discounts

Court accepts the net asset value and market approaches to valuing limited partnership interests, with discussion of discounts for lack of marketability, lack of control, and need for hard data.

Temple v. United States

In gift/estate case, Court considers discounts for lack of marketability and control for LLPs/LLCs and rejects flawed applications of QMDM and Mergerstat data.

Estate of Lorrain C. Disbrow v. CIR

The Tax Court determined that sec. 2036(a) applied to recapture of the value of a residence transferred to a general partnership and leased to the decedent where the decedent’s relationship to the residence did not materially change after the transfer, th ...

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