Court of Appeals Holds Commisioner to Published Revenue Rulings in Partnership and Annuity Transaction
Because the facts were not in dispute, the only question before the Court of Appeals was whether or not Gordon B. McLendon was sufficiently close to death on March 5, 1986, to require him to depart from the actuarial tables published by the Commissioner of Internal Revenue in valuing a remainder interest and related annuity.
Estate of E.L. Auker v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Tax Court Outlines Five-Point Test for Determining Market Absorption Discounts
The Tax Court handed down a five-point test for use when considering a market absorption discount (similar to a blockage discount).
Estate of Auker v. Commissioner
In this estate tax matter, the assets consisted of interests in several family-owned entities, the assets of which included real estate and interests in some of the family-owned entities that owned real estate.
Estate of Young v. Commissioner
Issues were whether properties were joint or community property, whether a marketability or fractional interest discount was applicable.
Estate of Welch v. Commissioner (I)
At issue is whether the estate of Welch is entitled to discount the value of stock for built-in capital gains taxes.
Estate of Furman v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Greg R. Vinikoor and Melissa D. Vinikoor v. CIR
The Tax Court determined that a transfer of stock was a gift rather than a loan even though the parties executed a note. The court listed nine factors it considered when determining whether the loan was a bona fide debt. Since the alleged debt did not me ...
Interfamily Transfer Determined to Be a Gift in Spite of Promissory Note
The Tax Court determined that a transfer of stock was a gift rather than a loan even though the parties executed a note.
Court Decides 44% Total Discount on Undivided Real Estate Parcels
The Tax Court decision in the case of Estate of Ellie B. Williams adds to the body of law on the valuation of undivided real estate interests.
Court Values Stock at Subsequent Sale Price
Although there are other assets at issue in this case, our review is limited to the value of 1,533.482 shares of a certain class of Sterling Holding Co. preferred stock as of the alternate estate valuation date, Sept. 18, 1992.
Dockery v. Commissioner
Issue is the value of petitioner's closely held stock in Crossroads Company, a reinsurance company domiciled in the Cayman Islands, that he gifted to his children.
Estate of McLendon v. Commissioner
Issue was whether McLendon was sufficiently close to death on March 5, 1986, to require him to depart from the actuarial tables in valuing a remainder interest and related annuity.
Estate of Williams v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Estate of Edna Pearce Lockett v. CIR
The Tax Court denied the estate a charitable deduction for property with historic significance held in trust because, while the decedent's trust granted the trustee power to dispose of the property based on the trust document, the decedent did not possess ...
Decedent’s Charitable Intent Required to Claim the Charitable Deduction
The Tax Court considered whether the estate could claim a charitable deduction for the donation of property with historic significance.
Tax Court Disallows Discount for Built-In Capital Gains
Respondent alleges deficiencies in petitioner's federal gift taxes owed for the years 1991, 1992, and 1993.
Estate of Trompeter v. Commissioner (I)
Issue was the fair market value of 1,533.482 shares of a certain class of Sterling Holding Co. preferred stock.
Court Allows Both Minority and Marketability Discounts for 50% Stock Interest
The issue is the value of a 50% stock interest in a small consumer loan company with a book value of $2,168,839.
Eric F. Saltzman, et al. v. CIR
The Second Circuit reversed and remanded the matter to the Tax Court after considered that a post-valuation date sale established the fair market value of the company. The company held a film library, whose title had been clouded. In order to insulate t ...
A Subsequent Sale Must Be Arm's Length and Foreseeable on the Valuation Date
The 2nd Circuit reversed and remanded the matter to the Tax Court after considered that a post-valuation date sale established the fair market value of the company.
Saltzman v. Commissioner
The pertinent discount issue in this case was the size of the marketability discount to apply to the fair market value of the stock in a family trust at the time of recapitalization.
Court Applies Discounts for Key Person and Pending Litigation in Estate Valuation
The issue is the fair market value of 1,226 shares of Paul Mitchell Systems common stock, constituting 49.04% of the shares outstanding, as of April 26, 1989, the date of Paul Mitchell's death.
Estate of Letts v. Commissioner of Internal Revenue
At issue is whether or not the decedent's estate includes the value of property that decedent's husband left to her.
Estate of Rosa N. Bullard v. U.S.A.
The U.S. District Court for the Eastern District of North Carolina determined that the estate was entitled to a refund for payment it included as alimony under IRC sec. 71 which were attributable to the parties' mortgage payment. In reaching this decisio ...