Estate of Kaufman v. Commissioner (I)
At issue is the valuation of the decedent's stock in a manufacturing company.
Estate of Grant v. Commissioner of Internal Revenue
At issue is respondent's valuation of stock.
Motion to Amend Granted
In response to a notice of deficiency, petitioner filed a petition alleging error in respondent's valuation of stock.
ABA Panel Calls for Elimination of Ancillary Business Restrictions
Alice Friedlander Kaufman (decedent) owned approximately 20% of the stock of Seminole Manufacturing Co. when she died.
Estate of Grant v. CIR
In this case, the petitioner sought leave to amend the petition to include facts learned from Freedom of Information Act requests regarding the agent's report on the valuation of the stock at issue in a deficiency notice.
Arm’s-Length Sales, Comparable Companies, and Elements of Control
The Tax Court valued a minority interest in a holding company that held a controlling interest in a uniform manufacturing company.
Estate of Richard R. Simplot v. Commissioner of Internal Revenue
At issue is the fair market value of decendent's stock in J.R. Simplot Co.
Estate of McMorris v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Adams v. U.S. (I)
At issue is the price that a hypothetical buyer would pay on the valuation date for a 25% assignee interest in a dissolved Texas general partnership.
Estate of Desmond v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
TAM 199909001
The Internal Revenue Service concluded in this technical advice that future lottery payments due to be received by a partnership should be valued by reference to the actuarial tables in section 20.2031-7(b)(6), and the present value of the payments should ...
Lottery Winnings Valued as Annuities
The Internal Revenue Service concluded in this technical advice that future lottery payments a partnership was due to receive should be valued by reference to the actuarial tables in section 20.2031-7(b)(6).
Henry E. Lundquist v. United States
The U.S. District Court for the Northern District of New York granted summary judgement to the IRS and against the taxpayer. The IRS determiend that a stock for note transaction was made for less than adequate compensation because, in part, the interest ...
Safe Harbor Interest Rate Does Not Apply When Valuing a Note for the Gift Tax
The U.S. District Court for the Northern District of New York granted summary judgement to the IRS and against the taxpayer.
Estate of Jameson v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Consideration of All Relevant Factors Makes 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.
Small Blockage Discount Supported by Post-Valuation Date Sales
The Tax Court permitted a blockage discount of 3.3% on the decedent's 2.2% interest in a NYSE stock.
Estate of Foote v. Commissioner of Internal Revenue
At issue is the fair market value of 280,507 shares of Applied Power, Inc. class A common stock held by the decedent.
Estate of Mellinger v. Commissioner of Internal Revenue
At issue is the valuation of the decedent's stock at death.
Estate of Ethel S. Nowell v. CIR
The Tax Court concluded that that estate should not aggregate the limited partnership units in which the decedent had a right to receive income for life (includable in the gross estate under IRC sec. 2038) with partnership units the decedent placed in tru ...
Aggregation of Partnership Interests Included in the Decedent’s Gross Estate Under Section 2044 and Section 2038 Improper
The Tax Court considered whether partnership units in which the decedent held the right to receive income for life should be aggregated with partnership units decedent placed in trust for estate tax purposes.
FSA 199919009
This field service advice concluded that restriction on liquidations on liquidation contained in a family limited partnership agreement were more restrictive than the applicable Missouri state law, and thus, the restrictions should be disregarded for valu ...
Valuation Discounts Rejected When Liquidation Provision Is More Restrictive Than State Law
The IRS stated its position with regard to looking through provisions in a partnership agreement preventing liquidation.
Estate of James C. Gibbs, Sr. v. CIR
The Third Circuit reversed the district court in this refund suit. The estate held farmland which was reported as qualified use property under IRC sec. 2032A. During the recapture period, the estate sold New Jersey a conservation easement in the property ...
Size of Voting Block Crucial to Premium
The issue for decision in these consolidated cases is the value of the gifts that the decedent made to his two sons, by means of a 1990 transaction in which he and his wife exchanged voting common stock in his closely held corporation for nonvoting common stock, with the result that his two sons ended up owning all of the voting stock of the corporation.