Discount Inappropriate in Valuing Indirect Gifts
The IRS ruled that valuation discounts should not be applied to the value of government bonds indirectly gifted to the donor’s children through their interests in an FLP.
Shepherd v. Commissioner (II)
Issues were characterization of ifts as indirect gifts and proper application of stipulated combined minority and marketability discount.
Heck v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Estate of Trompeter v. Commissioner (II)
The Ninth Circuit reversed the Tax Court’s valuation of closely held, preferred stock. It affirmed the Tax Court’s finding that the stock would be redeemed pursuant to its terms. However, it found the Tax Court’s present value calculation was not adequate ...
A Gross Result in the Gross Case Calls Into Question Circumstances in Which Tax Affecting Is Valid
Appraisers may soon have to defend their tax affecting in prior S corporation valuations as a result of Gross.
Daubert Issue Rears Its Ugly Head in Gross Case
George Hawkins wrote a guest abstract of this case in the January 2002 issue of Shannon Pratt's Business Valuation Update focusing on the tax affecting issues in the case.
Estate of Armstrong v. United States
The estate argued the "net gift doctrine," contending that the children's obligation to pay additional gift taxes as a condition of the gifts had substantially reduced the value of ...
40% 'Aggregate' Discount: Marketability, Control, and Unrealized Capital Gains
The IRS determined that decedent's estate owed amounts for estate tax and gift tax deficiencies.
5th Circuit Acknowledges Substantial Built-In Tax Liability on Timber Property
The issue on appeal was whether the Tax Court erred in the valuation of closely held stock and improperly denied a full discount for capital gains liability.
Tax Court Adopts 60% Fractional Interest Discount
This estates of John and Sarah Baird were consolidated for this proceeding.
District Court Applies Discounts to Partnership Interest on Remand
The Mendenhall estate consisted of a 25% assignee interest in Taylor Properties, a dissolved Texas general partnership.
Gross v. Commissioner (II)
Issues involved tax affecting of the discounted cash flows of the company and the size of the marketability discount.
0% Reduction for Tax Affecting Affirmed
The 6th Circuit affirmed the Tax Court’s valuation of gifted minority interests in a closely held S corporation.
FSA 200143004
The IRS enumerated its strategy to look through family corporations to reach the underlying assets of the corporation for gift tax purposes. The IRS instructed its agents to consider the economic substance doctrine, whether gifts were made on formation of ...
The IRS’ Strategy for Family Corporations
The IRS enumerated its strategy to look through family corporations to reach the underlying assets of the corporation for gift tax purposes.
Estate of Dailey v. Commissioner (I)
At issue are the valuation of certain retained and gift interests in a Family Limited Partnership (FLP).
Estate of Baird v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Buy-Sell Agreements Fail Lauder II Test and Are Considered Testamentary Devices
This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.
Estate of Eleanor T.R. Trotter v. CIR
The Tax Court, agreeing with the IRS, included the value of a condominium in the gross estate under IRC sec. 2036(a). The condo was transferred to a trust, but the decedent and her husband lived in the condo rent-free until her death, and the trust agreem ...
Value of Trust’s Property Included in Grantor’s Gross Estate
The Tax Court, agreeing with the IRS, included the value of a condominium in the gross estate under IRC sec. 2036(a).
Estate of Jameson v. Commissioner
At issue is whether the Tax Court erred in valuing assets of Johnco, Inc. ("Johnco"), a holding company that is part of the estate.
5th Circuit Reverses Tax Court's Capital Gains Discount 'Model'
The issue on appeal was whether the Tax Court erred in the valuation of closely held stock and improperly denied a full discount for capital gains liability.
Estate of Frank Branson v. CIR (Branson II)
The Ninth Circuit Court of Appeals determined that an estate was entitled to recoup capital gains taxes paid by the heir in connection with the sale of the estate’s stock. A professional appraiser valued the stock and that value was included in the gross ...
Equitable Recoupment Applied
The 9th Circuit Court of Appeals determined that an estate was entitled to recoup capital gains taxes the heir paid in connection with the sale of the estate’s stock.
Shackleford v. United States
At issue is whether a statutory anti-assignment restriction on lottery payments justifies departure from the Department of Treasury's annuity tables when determining the asset's present value.