Gross v. Commissioner (I)
Business Valuation and Taxes: Procedure, Law and Perspective ...
DCF Method Appropriate for Valuing General Contractor
In 1992, May Rakow gave 1,780 shares of Illinois Hydraulic Construction Co. (IHC) stock to her children and grandchildren.
Estate of Magnin v. Commissioner of Internal Revenue
At issue is the value of the remainder interest of the family corporation and the life and voting interest of the stock in the family corporations.
Estate of Branson v. Commissioner of Internal Revenue
At issue is the fair market value of decendent's stock acquisitions.
Estate of Magnin v. CIR
The primary issue in this case is whether the decedent received full and adequate consideration under an agreement entered into with his father.
Backlog of Willing Buyers Offsets Marketability Discount
The primary issue in this estate tax matter is the fair market value of 12,889 shares of Savings Bank of Mendocino County (Savings) stock, and 500 shares of Bank of Willits (Willits) stock, owned by decedent on the date of his death.
Estate of Cartwright v. Commissioner (II)
At issue is the valuation of the deceased's share of stock in a law firm in which he was the majority shareholder.
Stockholders' Agreement Controls Character of Insurance Proceeds
Robert E. Cartwright was the majority shareholder, primary rainmaker, and driving force behind the law firm of Cartwright, Slobodin, Bokelman, Borowsky, Wartnick, Moore & Harris Inc. (CSB).
Work in Progress Should Be Considered When Valuing a Law Firm
The 9th Circuit Court of Appeals affirmed and reversed a Tax Court decision, valuing stock in a law practice.
Estate of Ambrosina Blanche Lopes v. CIR
The Tax Court concluded that fractional interests in real property includable the gross estate under IRC sec. 2036 and the decedent's right to receive income from the same properties from a trust includible in her estate under IRC sec. 2044 should not be ...
Aggregation Denied
The Tax Court considered a motion for summary judgment regarding whether undivided interests the estate owned and included in the gross estate under IRC sec. 2036 should be aggregated with interests included in the same estate under IRC sec. 2044.
Frederick's of Hollywood Stock Not Aggregated for Valuation; 25% Blockage Discount Applied
Decedent, the widow of Frederick N. Mellinger, held Frederick's of Hollywood stock in three capacities: (1) as income beneficiary of a QTIP irrevocable marital trust her predeceased husband established under IRC § 2056(b)(7); (2) as beneficiary of a revocable trust that she established herself; and (3) 50 shares outright.
Holding Company Valued Using Asset Method; Small Marketability Discount Applied
The primary issue in this estate tax matter was the fair market value of decedent's 98% stock interest in Johnco Inc., a holding company with timberland as its principal asset.
Potential Environmental Liability Relevant to Fair Market Value
This is another Tax Court opinion with a thorough discussion of business valuation methods, discounts and premiums, and relevant factors to be considered.
TSA 199938005
The IRS ruled that an estate should include the value of decedent's one-half interest in a closely-held corporation under IRC sec. 2036(b). The decedent transferred the 55-percent of his stock to a limited partnership which he controlled. The Service co ...
Value of Stock Included in Gross Estate When Stock Is Controlled Through a Partnership
The IRS ruled that an estate should include the value of decedent's one-half interest in a closely held corporation under IRC sec. 2036(b).
Tax Court Accords Superpremium to Small Voting Block and Allows Deduction of 100% of Trapped-In Capital Gains Tax
Chris Mercer, president of Mercer Capital Management Inc., a leading independent business appraisal firm, abstracts and analyzes what is sure to be one of the most discussed U.S. Tax Court of 1999.
Taxpayer's Expert 'Unpersuasive'; Record Doesn't Meet Burden of Proof; IRS Wins by Default
Alice Friedlander Kaufman owned approximately 20% of the stock of Seminole Manufacturing Co. when she died.
Taxpayers Lose Charitable Gift Deduction
Taxpayers John T. Hewitt and Linda L. Hewitt claimed charitable contribution deductions on their 1990 and 1991 income tax returns.
Relevant Factors Make Expert's Conclusion More Reliable
The issue in this estate tax matter is the appropriate blockage discount, if any, to apply in valuing decedent's shares of Applied Power stock.
Rakow v. Commissioner
At issue is the fair market value of stock given by petitioner to her children and grandchildren.
Estate of Rodgers v. Commissioner of Internal Revenue
At issue is is the fair market value of the interest that Lynn M. Rodgers (decedent) owned on the date of his death in Marrero Land and Improvement Association, Limited.
Absorption Discount Applied to Value Assets
The issue in this estate tax matter is the valuation of decedent's 166 2/3 shares of stock representing one-third of the total of Marrero Land, a real estate operating company that engages in "the business of acquiring, developing, managing, improving, maintaining, leasing, and selling real estate."
Michael Ferguson, et al. (Ferguson II) v. CIR
The U.S. Court of Appeals for the Ninth Circuit applied the anticipatory assignment of income doctrine and determined that the taxpayers were liable for the capital gain on appreciated stock they donated to a charitable organization. The stock was transf ...
Donors Liable for Gain in Appreciated Stock Under Anticipatory Assignment of Income Doctrine
The U.S. Court of Appeals for the 9th Circuit applied the anticipatory assignment of income doctrine and determined that the taxpayers were liable for the capital gain on appreciated stock they donated to a charitable organization.