Fair Market Value Trumps IRS Valuation Tables
In 1987, Thomas J. Shackleford bought a California Lottery ticket for $1 and won the jackpot.
Adams v. U.S. (III)
The U.S. District Court for the Northern District of Texas applied valuation discounts in determining the value of an assignee interest in a dissolved Texas general partnership. The District Court adopted the discounts proposed by the estate’s expert-- a ...
Assignee Interest Not Subject to Liquidation Rights
The U.S. District Court for the Northern District of Texas applied valuation discounts in determining the value of an assignee interest in a dissolved Texas general partnership.
Estate of O'Neal v. United States
At issue is the valuation date of the value of a deduction claimed by the estate.
11th Circuit Holds Claims Against Estate Do Not Include Post-Death Events
This is an appeal from the United States District Court for the Northern District of Alabama.
Estate of Schwan v. Commissioner
At issue is the valuation of the decedent's stock in a closely-held corporation for purposes of computing the gross estate and the allowable charitable deduction under Federal tax laws.
Redemption Agreement Did Not Affect Value of Decedent's Estate
The petitioners in this case, decedent's estate and a charitable foundation (the Martin M. Schwan Foundation), challenged the IRS' determination that the estate had a tax deficiency based on a bequest to the foundation and that the foundation was liable as a transferee.
Estate of Cook v. Commissioner
At issue is the value at decedent's date of death of her interest in a limited partnership.
Tax Court Values Partnership Interest in Future Lottery payments
This estate tax case concerns 19 annual installment payments of lottery winnings to a limited partnership in which the decedent held a 2% general partnership interest and a 48% limited partnership interest.
Estate of True v. Commissioner
1Cases of the following petitioners are consolidated herewith: Jean D. True, docket No. 3408-98 and Estate of H.A. True, Jr., Deceased, H.A. True, III, Personal Representative, docket No. 3409-98. T.C. Memo. 2001-167 UNITED STATES TAX COURT ESTATE OF H.A. TRUE, JR., DECEASED, H.A. TRUE, III, PERSONAL REPRESENTATIVE, AND JEAN D. TRUE, ET AL.1, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 10940-97, 3408-98, Filed July 6, 2001. 3409-98. Buford P. Berry, Emily A. Parker ...
Buy-Sell Agreements Are 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.
Buy-Sell Agreements Do Not Control for Estate Tax Purposes
The Tax Court considered whether buy-sell agreements controlled the value of the business interests the decedent held for estate and gift tax purposes.
Succession of Betty Felix Helis v. U.S.A.
The Court of Federal Claims valued a 50 percent partnership interest. The IRS’s expert applied a 13 percent minority discount to the real property assets of the partnership. This discount was determined using Mergerstat data and reduced because the IRS fo ...
Minority Discount Applies to All Partnership Assets
The Court of Federal Claims valued a 50% partnership interest.
Tax Court Upholds Estate's Fractional Discount for Minority Interest Held by Limited Partnership
This valuation dispute arose from the undivided real estate interest held by the Forbes QTIP trust.
Simplot Reversed by 9th Circuit; Control Premium for Voting Shares Incorrectly Applied
This case is the 9th Circuit Court of Appeals' decision on appeal of Estate of Simplot v. Commissioner, 112 T.C. No.13 (1999), which was abstracted in the May 1999 issue of Shannon Pratt's Business Valuation Update.
9th Circuit Vacates and Remands Tax Court's Valuation in Mitchell
In this ongoing estate tax proceeding, the Estate of Paul Mitchell (Estate) appealed the U.S. Tax Court's decision allowing the Commissioner of the IRS to assess an additional $2,404,571 in federal estate taxes.
Estate of Paul Mitchell v. CIR
The U.S. Court of Appeals for the Ninth Circuit reversed the Tax Court’s valuation of a minority interest in a hair care products company. The Tax Court received testimony from both parties regarding the value of the business using a public guideline comp ...
Combined Discount Must Be Thoroughly Explained
The U.S. Court of Appeals for the 9th Circuit reversed the Tax Court’s valuation of a minority interest in a hair care products company.
Estate of Simplot v. Commissioner (II)
Ninth Circuit reversed and ordered entry of judgment in favor of the estate on remand because the Tax Court erroneously attributed a premium to minority voting stock.
Estate of Hoffman v. Commissioner
At issue is the fair market value of property interests held by decedent at the time of her death.
Patricia A. and John C. Schott v. CIR (Schott I)
The Tax Court concluded that grantor retained annuity trusts (GRATs) from the plaintiffs should be valued as single life annuities rather than dual life annuities. It reached this decision after considering the fact that the grantor of each trust retained ...
GRATs Valued as Single Life Annuity
The Tax Court concluded that grantor retained annuity trusts (GRATs) from the plaintiffs should be valued as single life annuities rather than dual life annuities.
Appraisers Apply Myriad of Valuation Techniques to Various Estate Holdings
Marcia Hoffman's (decedent) estate held a 27.5% interest in Clubside Partnership, which was family owned.
Estate of Mitchell v. Commissioner (II)
Estate claimed Tax Court erred by failing to provide a detailed explanation of the methodology used to calculate FMV, miscalculating the value, and failing to shift the burden of proof.