Knight v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
WACC Rejected as Value Measure
The issue in this estate tax matter is the fair market value of decedent James J. Renier's 88.4% interest in the Renier Co., a family-owned electronics retailer in Dubuque, Iowa.
Tax Court Determines Capital Gains Discount for Real Estate Holding Company
This issue in this estate tax matter is the fair market value of decedent's 82.76% interest in Valley Improvement Co. Inc. (VIC), a real estate holding company, as of Jan. 12, 1994.
Tax Court Rejects IRS Bid to Overrule Kerr v. Commissioner
The issue in this estate tax matter is whether the provisions of the Limited Partnership Agreement for Harper Financial Co. LP, entered into by the decedent and his two children, were "applicable restrictions" for purposes of IRC § 2704.
Shepherd v. Commissioner (I)
At issue is the fair market value of petitioner's transferred real estate interests.
Renier v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Tax Court Rejects Unsupported Valuation Methods and WACC
The issue in this estate tax matter is the fair market value of decedent James J. Renier's 88.4% interest in the Renier Co., a family-owned electronics retailer in Dubuque, Iowa.
Income Approach Used to Value Retail Consumer Electronics Business
The Tax Court valued a controlling interest in a consumer electronics business.
Option With No Bona Fide Business Purpose Not Relevant to FMV
This case deals with the valuation for estate tax purposes of four Housing and Urban Development (HUD) housing partnerships and one real estate management partnership.
Borgatello v. Commissioner
T.C. Memo. 200-264 UNITED STATES TAX COURT ESTATE OF CHARLES A. BORGATELLO, DECEASED, C. NORMAN BORGATELLO AND JOSEPHINE E. DONNELLY, CO-EXECUTORS, AND C. NORMAN BORGATELLO, SUCCESSOR TRUSTEE TO THE CHARLES A. BORGATELLO LIVING TRUST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24756-97. Filed August 18, 2000. John W. Ambrecht and Gregory Arnold, for petitioners. Donna F. Herbert, for respondent. MEMORANDUM OPINION WELLS, Chief Judge: Respondent determined a deficiency of $3,424,504 in the ...
Tax Court Allows Capital Gains Discount for Real Estate Holding Company
The issue in this estate tax matter is the fair market value of decedent's 82.76% interest in Valley Improvement Co. Inc. (VIC), a real estate holding company, as of Jan. 12, 1994.
Built-In Capital Gains Considered in Build Up of the Marketability Discount
The Tax Court valued a real estate holding company using the net asset value method.
Estate of Edward H. Eddy v. CIR
The Tax Court refused to permit the estate to use the alternate valuation date because the estate's tax return was filed beyond the time prescribed by law. It additionally permitted the application of a blockage discount (which was uncontested by the IRS ...
Blockage Discount Applied to Small Block of Public Stock
The Tax Court refused to permit the estate to use the alternate valuation date because the estate's tax return was filed beyond the time prescribed by law.
Estate of Godley v. Commissioner (I)
At issue in the equitable distribution litigation was the value of Fred Jr.'s 50-percent general partnership interest in the partnerships.
6th Circuit Allows Capital Gains Discount
The issue in this estate tax appeal is whether the petitioners were entitled to apply a discount for a built-in capital gains tax liability on real estate in valuing the stock of the corporation owning the real estate.
Court Accepts Small Size Risk Premium, Adjustment to Multiples
This case is important because it supports the use of the small stock premium in developing a discount rate and also the adjustment of market valuation multiples in the guideline public company method.
Adams v. U.S. (II)
At issue is whether discounts for lack of control, lack of marketability, and poor portfolio diversity are applicable when appraising the value of an assignee's fractional interest in a Texas general partnership for estate tax purposes.
Harper v. Commissioner
At issue is whether, pursuant to section 2704(b), restrictions on the right to liquidate certain limited partnership interests in Harper Financial Co., L.P., should be disregarded.
Tax Court Rejects IRS Bid to Overrule Kerr
The issue in this estate tax matter is whether the provisions of the Limited Partnership Agreement for Harper Financial Co. LP the decedent and his two children entered into were "applicable restrictions" for purposes of IRC § 2704.
A Gift to the 'Next Generation'
The issue in this case is whether the decedent's redemption of 567 shares to Pepsi-Cola Alton Bottling Inc. (PCAB) was indeed a gift to her son, who ran the company.
Estate of Klauss v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Lavonna J. Stinson Estate (Stinson II) v. United States of America
The Seventh Circuit affirmed the district court's finding that the forgiveness of corporate debt is not a gift of a present interest to the corporation's shareholder, and, therefore, the annual gift tax exclusion could not be claimed. It additionally agr ...
Annual Exclusion May Not Be Applied to the Forgiveness of Corporate Debt
The 7th Circuit affirmed the district court's finding that the forgiveness of corporate debt is not a gift of a present interest to the corporation's shareholder, and, therefore, the annual gift tax exclusion could not be claimed.
Blockage Discount Appropriate for Apartment House
The taxpayer was granted a 20% fractional interest discount and an 11% blockage discount with apartment house properties, based on comparable sales and an analysis of market conditions and the economy.