‘Alimony Payments’ Are Part Property and Part Taxable Alimony
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.
John T. & Linda L. Hewitt (Hewitt I) v. CIR
The full Tax Court concluded that a taxpayer who donated stock to a charitable organization was not entitled to a deduction greater than their basis in the stock. The stock was closely held and thinly traded through the company. The taxpayer failed to c ...
Qualified Appraisal Required to Substantiate Value of Charitable Donation
The full Tax Court concluded that a taxpayer who donated stock to a charitable organization was not entitled to a deduction greater than their basis in the stock.
Court Utilizes DCF Valuation Method, Decries Failure to Consider Willing Seller
At date of death, decedent owned a 1% general partnership interest and a 23.9650903% limited partnership interest in LKB Associates, a limited partnership organized under the laws of the District of Columbia.
Price Set Arbitrarily; Buy-Sell Price Not Controlling for Estate Tax
The issue is the effect, if any, of a buy-sell agreement on the value of shares of CamVic Corp. that are includable in the estate of Cameron W. Bommer (decedent).
Fleming v. Commissioner
At issue is the fair market value of the stock interest in a small loan company that was owned by Thomas A. Fleming (decedent) at the date of his death.
Eisenberg v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Estate of Mitchell v. Commissioner (I)
The issue is the fair market value of 1,226 shares of Paul Mitchell Systems common stock, constituting 49.04% of the shares outstanding.
Estate of Mary D. Maggos (Maggos I) v. CIR
The Tax Court rejected taxpayer's motion for summary judgment on gift tax liability resulting from a redemption of a majority interest in a corporation's stock. The transaction left the decedent's son as the sole shareholder of the corporation. The IRS d ...
Independent Appraisal Needed to Overcome Presumption of Donative Intent
The Tax Court rejected taxpayer's motion for summary judgment on gift tax liability resulting from a redemption of a majority interest in a corporation's stock.
Deposits of FLP Income to Personal Bank Account Cause Disallowance of Gifts
The decedent, Dorothy Schauerhamer, established three partnerships to which she gifted assets, primarily commercial real estate.
Lehmann v. Commissioner
At issue is whether petitioner correctly valued the partnership interests in LKB Associates for purposes of decedent's gross estate.
Bommer Revocable Trust v. Commissioner
At issue is the effect, if any, of a restrictive stock agreement on the value of certain stock in CamVic Corp. that is includable in the Estate of Cameron W. Bommer.
Taxpayer Hurt in Undivided Timberland Case
At issue is the fair market value of a 25% undivided interest in timberland Barge owned, which was the subject of gifts Barge made in 1987.
Transfer of Property's Qualification for Gift Exclusion at Issue
At issue is whether or not the transfer of property in an irrevocable trust is eligible under section 2503(b) for the annual $10,000 gift exclusion with respect to each of 16 contingent beneficiaries of the trust.
Wheeler v. United States
Issue is whether sale of remainder interest for less than value of full fee simple interest in ranch constitutes adequate consideration for the purposes of section 2036(a).
Schauerhamer v. Commissioner
At issue is whether the value of certain assets transferred to family partnerships is includable in the decedent's gross estate.
Family Limited Partnership Disregarded Where Decedent Used Partnership Funds for Personal Expenses
The Tax Court concluded that three family limited partnerships should be disregarded and the value of their assets included in the value of the decedent's gross estate under IRC sec. 2036.
Estate of Verdon Gavin v. United States of America
The Eighth Circuit reversed the district court and permitted an IRC. Sec. 2032A election. Here the qualified heir was one of seven heirs to a family farm. The qualified heir operated the farm under a lease granted under the decedent's will, until the hei ...
Qualified Heir(s) Defined for Section 2032A Election Purposes
The 8th Circuit reversed the district court and permitted an IRC. Sec. 2032A election.
Kohlsaat v. Commissioner
At issue is whether, in the computation of petitioner's Federal estate tax, decedent's inter vivos transfer of property to an irrevocable trust is eligible under section 2503(b) for the annual gift tax exclusion.
Michael Ferguson, et al. (Ferguson I) v. CIR
The Tax Court concluded that individuals who transferred appreciated stock to a charitable organization should be liable for the gain on the stock. The court applied the anticipatory assignment of income doctrine to the charitable donation. In this case ...
Court Rejects Hypothetical Control Premium Scenario
At issue is the value of Clyde Wright's 201,408 shares of common stock of the Wilber Corp., which owns 100% of the common stock of Wilber National Bank.
Estate of Barge v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Estate of William F. Sharp, Jr. v. U.S.A.
The District Court for the Eastern District of Tennessee determined that a funeral home business had goodwill. The parties stipulated to the value of the business' assets. After the decedent died, his children operated the business and made substantial ...