Stock Repurchase Agreement Not Controlling; Tax Court Applies 40% Marketability Discount
Ann Brookshire owned 219,710 shares of common stock in Brookshire Grocery Co., representing 9.79% of the total shares outstanding, at the time of her death on Nov. 20, 1993.
Hewitt v. Commissioner of Internal Revenue
At isssue is whether the parties are entitled to certain charitable contribution deductions.
Louise B. Barnes, donor, et al. v. CIR
The Tax Court valued gifts of less than a one percent interest in two closely held regional telephone companies. It accepted the taxpayer's valuation using the market comparison of actual dividends paid. It rejected the inclusion of a small stock premium ...
Small Stock Risk Premium and Lack of Marketability Discount Considered
The Tax Court valued gifts of less than a 1% interest in two closely held regional telephone companies.
2nd Circuit Reverses Eisenberg, Allows Discount for Capital Gains Tax
This decision reverses the U.S. Tax Court decision, which disallowed a discount from net asset value reflecting potential capital gains taxes for a C corporation with a piece of commercial real estate as its major asset.
Appellate Court Decides Redemption Price Controls Based on Treasury Regulations
The only issue in this case is whether the price in a stock redemption agreement entered into between the decedent and the corporation is determinative for estate tax purposes.
Brookshire v. Commissioner
At issue is the value, as of the date of decedent's death, of 106,826 shares of common stock of a closely held family corporation.
Lavonna J. Stinson Estate (Stinson I) v. United States
The district court found that forgiveness of corporate debt was not a gift of a present interest to the corporation's shareholder, and, therefore, the annual gift tax exclusion could not be claimed by the donor. It additionally agreed that the gift is va ...
Gift Tax Assessed on Cancellation of Indebtedness
The district court found that forgiveness of corporate debt was not a gift of a present interest to the corporation's shareholder, and, therefore, the donor could not claim the annual gift tax exclusion.
Case Addresses Fine Points of 'Moment of Death' Issue; IRS Concedes 15% Discount of Blockage
The issue before the Court of Appeals was whether Charles K. McClatchy's stock holdings should be valued with the federal securities law restrictions that had been in place before his death or without the restrictions once they were transferred to his estate.
Tax Court Recognizes Discount for Trapped-In Capital Gains
The issue in this case was the value of each of two 25-share blocks (out of 97 shares outstanding) of ADDI&C, gifted on Nov. 21, 1992.
Eisenberg v. Commissioner
At issue is the valuation reduction for capital gains tax liabilities of appellant's gifted shares of stock.
Estate of Gloeckner v. Commissioner
Issue in this case is whether the price in a stock redemption agreement entered into between the decedent and the corporation is determinative for estate tax purposes.
Estate of Thomas J. Shackleford (Shackleford I) v. United States of America
The U.S. District Court for the Eastern District of California considered whether unreceived lottery payments should be valued as a commercial annuity or as a private annuity including deviations from the annuity tables for lack of marketabilty. The cour ...
Lottery Payments Must Be Valued as Private Annuities
The U.S. District Court for the Eastern District of California considered whether unreceived lottery payments should be valued as a commercial annuity or as a private annuity including deviations from the annuity tables for lack of marketability.
Court Disallows Built-In Capital Gains Discount
At issue is whether the estate of Welch is entitled to discount the value of stock for built-in capital gains taxes, causing a deficiency of $59,987 in federal estate taxes.
Young v. Commissioner
Respondent determined an estate tax deficiency of $154,545.
Estate of Bosca v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Estate of Davis v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Court Accepts Discounted Dividend Method, 40% Discount for Lack of Marketability
At issue is the value of petitioner's closely held stock in Crossroads Co., a reinsurance company domiciled in the Cayman Islands, that he gifted to his children on Jan. 1, 1992, and and Jan. 1, 1993.
Tax Court Applies 40% Combined Discount to Arrive at Fair Market Value
Before the Tax Court, for purposes of determining the taxable gifts of Royal G. Furman, and the taxable gifts and taxable estate of Maude G. Furman, is the determination of the fair market value of shares in Furman's Inc. (FIC), a closely held company.
McClatchy v. Commissioner
At issue is the valuation of decendent's stock in a newspaper corporation for federal estate tax purposes.
SEC Rule 144 Discount May Be Applied in Estate Tax Valuations
The 9th Circuit reversed the Tax Court's decision denying the estate a discount for SEC Rule 144 restrictions.
Estate of Suzanne W. Cullison v. CIR
The Tax Court determined that the decedent did not receive adequate and full consideration when she transferred real property to her children in exchange for a private annuity. The court determined that the taxpayer's accountant provided them with faulty ...
Accountant’s Faulty Tax Advice Results in an Indirect Gift From Decedent
The Tax Court determined that the decedent did not receive adequate and full consideration when she transferred real property to her children in exchange for a private annuity.