Fractional Interest and Blockage Discount Considered
The Tax Court considered the size of discounts for blockage and fractional interests on nine rental properties.
Adams v. United States (I)
The dispute in this case focuses on disagreement regarding discounts that the court should apply to reach the actual value of a 25% assignee interest.
Petitioners' expert accepted despite their claim of lower value
The Experts: Clifford Braly III (for taxpayers on returns) Deloitte & Touche Management Planning, Inc. (for petitioners at trial) William H. Frazier, ASA (for petitioners ...
Estate of DiSanto v. Commissioner
At issue is the fair market value of a block of 186,177 shares of MD&F stock owned by the decendent.
Petitioners' Expert Accepted Despite Their Claim of Lower Value: Marital Deduction Based on Stock Actually Inherited After Disclaimer
The issues in the estate tax matter were: the fair market value of Frank DiSanto's (Frank) 186,177 shares (53.5%) of stock in Morganton Dyeing & Finishing Corp. (MD&F) on the date of death; the fair market value of the MD&F stock Grace DiSanto (Grace) was entitled to inherit from Frank's estate (a minority interest) on her date of death; whether Grace had expectancy interest only in the stock she was entitled to inherit; and whether Frank's estate was entitled to a marital deduction based on the value of the stock he willed to Grace or based on the value of the stock she was entitled to receive after executing a disclaimer of part of her interest in the stock.
A Post-Valuation Date Redemption and a Marital Deduction
The Tax Court determined that the fair market value of stock in a fabric dying corporation.
Kerr v. Commissioner (I)
At issue is the valuation of the FLP interests for federal gift tax purposes.
Taxpayers Transferred FLP Interests in Form and Substance
The Tax Court has issued the first guidance on some of the tax issues facing family limited partnerships (FLPs) in this gift tax case.
FLP’s Liquidation Provisions Must Be Considered When They Are Not More Restrictive Than State Law
The Tax Court granted the Kerrs' motion for summary judgment.
Tax Court Holds Sales Transactions Not Indicative of FMV
This issue in this estate tax matter was the fair market value on Sept. 7, 1993, of decedent's 366,385 shares of common stock of Hastings Books, Music & Video Inc.
Estate of Smith v. Commissioner
At issue is the value of Smith's shares of stock in two companies, Jones Farm Inc., and First National Bank of Waverly, as of her death.
Court Accepts Taxpayer's 76% Discount on Farm Corporation
The estate in this case held minority interests in two companies: Jones Farm Inc. (JFI) (33% ownership of common stock) and in the First National Bank of Waverly (FNBW) (12% of common stock).
Court Rejects Inadequate DCF; Selection of Comparables Critical 30% Lack of Marketability Discount for Controlling Interest
The issue in this estate tax case was the fair market value of decedent's 1,499 shares of Peoples Trust and Savings Bank of Boonville, Ind., constituting 49.97% of the 3,000 shares outstanding.
Estate of Marmaduke v. Commissioner of Internal Revenue
At issue is the fair market value, as of the date of decedent's death, of 366,385 shares of common stock of a closely held corporation.
Small-Block Sales Not Indicative of FMV; 30% Marketability Discount Applied
The issue in this estate tax matter was the fair market value on Sept. 7, 1993, of decedent's 366,385 shares of common stock of Hastings Books, Music & Video Inc., a closely held corporation.
Illiquidity Increases With Block Size
The Tax Court determined the fair market value, including a discount for lack of marketability, of a large block of stock in a retail books, music, and video chain operating in the South and Southwest.
Not Necessary to Tax Affect Pepsi Bottler S Corp Earnings
Petitioners in this case were gifted a total of 373.5 shares of common stock out of 19,680 outstanding shares in G&J Pepsi-Cola Bottlers Inc. (an S corporation) from their parents, and each filed a Form 709 (United States Gift and Generation Skipping Transfer Tax Return) in a timely manner.
Insurance Proceeds Not an Asset
Robert Cartwright was the majority shareholder, primary rainmaker, and driving force behind the law firm of Cartwright, Slobodin, Bokelman, Borowsky, Wartnick, Moore & Harris Inc. (CSB).
Estate of Hendrickson v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Court Rejects Inadequate DCF; Selection of Comparables Critical
The issue in this estate tax case was the fair market value of decedent's 1,499 shares of Peoples Trust and Savings Bank of Boonville, Ind., constituting 49.97% of the 3,000 shares outstanding.
Appropriate Consideration of Comparable Companies Necessary When Using the Public Guideline Company Approach
The Tax Court considered the valuation of a single-location commercial bank that acted like a thrift.
Estate of Robert L. Snyder v. United States of America
The Court of Federal Claims permitted the estate to deduct a environmental liability settlement over the objection of the IRS. The estate held a landfill in a trust. The Landfill was a Superfund site on the 1986 date of death. In 1997, the environmental ...
Environmental Litigation Settlement Deductible From the Gross Estate
The Court of Federal Claims permitted the estate to deduct a environmental liability settlement over the objection of the IRS.
Estate of Thomas J. Shackleford (Shackleford II) v. United States of America
The district court concluded that the decedent's remaining lottery payments should be valued by reference to the "gray market" even though the payments bore an absolute restriction on their transfer, instead of by reference to the annuity tables in 26 USC ...
Future Lottery Payments Valued by Reference to the Gray Market
The U.S District Court for the Eastern District of California considered the value of future lottery payments.