Tax Court Determines That Value Was 'Somewhere in the Middle' of Expert Opinions
The taxpayers' expert, Gregory Heebink, used the discounted cash flow (DCF) method and the guideline public company method.
7th Circuit Affirms Tax Court; Gifts Were of Future Interests
This opinion is the 7th Circuit Court of Appeals’ ruling on appeal from the Tax Court opinion of Hackl v. Commissioner, 118 T.C. 279 (U.S. Tax Ct. 2002).
Peracchio v. Commissioner
Issues were appropriate discount for lack of control and discount for lack of marketability to apply in valuing gifts of family limited partnership interests.
Lappo v. Commissioner
The issue for decision is the fair market value of interests in a family limited partnership that petitioner transferred in 1996.
Tax Court Accepts Negative Industry Risk Premium and Unique Combined Discount Matrix
The decedent, Helen Deputy, formed a family limited partnership comprised of 99% of a limited partnership interest retained by Deputy and two 0.5% general partnership interests, one held by Deputy and one held by her son.
Estate of Gribauskas v. CIR (Gribauskas II)
The U.S. Court of Appeals for the Second Circuit reversed the Tax Court's valuation of payments from the Connecticut Lotto. The estate valued the payments based on the gray market, inclusive of a lack of marketability discount. The Tax Court ruled that th ...
Value of Lotto Payments Includes Discount for Lack of Marketability
The U.S. Court of Appeals for the 2nd Circuit reversed the Tax Court's valuation of payments from the Connecticut Lotto.
Hess v. Commissioner
Taxpayers gave 10 shares of HII common stock (a 10% stockholder interest) to an irrevocable trust established for their daughter. Issue was the fair market value of the stock for gift tax p ...
Tax Court Rejects Pre-IPO Studies, Finds DLOM Accounts for More Than Illiquidity
Petitioners Charles T. and Mary S. McCord gifted interests in McCord Interests Ltd. LLP (MIL) to their four children, trusts for the benefit of the children, and two charitable organizations by way of assignment agreements.
Tax Court Rules on Remand That IRC Section 2036 Applies
The original Tax Court ruling in this case was Estate of Strangi v. Commissioner, 115 T.C. No. 35 (U.S. Tax Ct. Nov. 30, 2000).
Hackl v. Commissioner (II)
Issue was whether restrictions on transfer in operating agreement meant that the gifted shares were "essentially without immediate value to the donees."
Tax Court Rejects Experts' Testimony; Tax Return Value Prevails
The issue in this estate tax matter was the fair market value of all 20,000 outstanding shares of Harlee International Inc ., a family-owned S corporation that was an importer and wholesale-distributor of futon and waterbed frames.
Estate of Deputy v. Commissioner
Issue was the fair market value of a 19.99% interest of stock owned by an FLP, and court discussed negative industry risk premium and unique matrix for determining marketability discount.
Estate of Strangi v. Commissioner (III)
Issue on remand is whether the value of property transferred is includable in his gross estate pursuant to section 2036(a).
McCord v. Commissioner (I)
Business Valuation and Taxes: Procedure, Law and Perspective ...
Estate Fails to Meet 2036(a) Requirements; Partnership's Assets Included in Gross Estate
After decedent's death, her estate filed returns listing the value of decedent's 99% partnership interest as $1.257 million.
Estate of Leichter v. Commissioner
The issue in this estate tax matter was the fair market value of all 20,000 outstanding shares of Harlee International, Inc., a family-owned S corporation.
Valuation Reports Must Provide Sufficient Detail
The Tax Court considered the valuation of a closely held S corporation.
IRS Reliance on Valuation Position Substantially Justified
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.
Estate of Duilio Costanza (Costanza II) v. CIR
The U.S. Court of Appeals for the Sixth Circuit determined that an intrafamily transaction involving a self-canceling installment note (SCIN) was a bona fide transaction within the meaning of IRC sec. 2001(b). In making its determination, the appellate co ...
Intrafamily Sale Determined a Bona Fide Transaction
The U.S. Court of Appeals for the 6th Circuit determined that an intrafamily transaction involving a self-canceling installment note (SCIN) was a bona fide transaction within the meaning of IRC sec. 2001(b).
Patricia Schott v. CIR (Schott II)
The U.S Court of Appeals for the Ninth Circuit reversed the Tax Court and concluded that grantor retained annuity trusts established for the life of the grantor and the life of the grantor’s spouse, if the grantor dies before the expiration of the GRAT, w ...
Interest From Dual-Life Annuity Qualifies Under Sec. 2702
the U.S. Court of Appeals for the 9th Circuit determined whether interest from grantor retained annuity trusts (GRATs) qualified as dual-life annuities for gift tax purposes.
Lack of Marketability Discount Is Not Permitted on U.S. Bonds
The IRS determined that a lack of marketability discount could not be applied to the value of U.S. government Series E savings bonds.
TAM 200303010
The IRS determined that a lack of marketability discount could not be applied to the value of U.S. Government Series E savings bonds. It found that the willing buyer-willing seller standard did not apply because the only willing buyer was the U.S. Govern ...