IRS’ Valuation of Funeral Home Fatally Flawed
The District Court for the Eastern District of Tennessee determined that a funeral home business had goodwill.
Estate of Jewell E. Gray v. CIR
The Tax Court determined that money received by the decedent, labeled as loans, was, in fact, dividends from her personal holding company. In reaching this decision the court listed a twelve-question analysis. The court also determined that the business ...
Two Discounts and a Related Party Transfer
The Tax Court determined that money by the decedent received, labeled as loans, was, in fact, dividends from her personal holding company.
W. Clyde Wright v. Commissioner
At issue is the valuation of decendant's 201,408 shares of common stock of the Wilber Corp.
Court Awards 30% Discount for Lack of Marketability
The taxpayer's motion for administrative cost recovery was the basis of this case.
Partnership Valuation Focuses on Minority, Marketability Discounts
The issue is the value of one general partnership unit (out of 95) in FC Partners as of decedent's date of death, Dec. 31, 1989.
Judge Laro Rejects Motion to Value Partnership Only on Going Concern Premise
In this case, the personal representative of the deceased asked the court for partial summary judgment by asserting "the Court must use a going concern methodology to value a 20% partnership interest."
Estate of D'Ambrosio v. Commissioner
Issue is whether entire fee simple value of stock was part of gross estate even though the decedent had sold her remainder interest in the stock for its fair market value.
Remainder Interest Included in Gross Estate at FMV
The 3rd Circuit reversed the Tax Court and concluded that the decedent received adequate consideration under IRC sec. 2036 when she exchanged her stock for an annuity.
Theodore W. Van Zelst, et al. v. CIR
The U.S. Court of Appeals for the Seventh Circuit rejected the donor's charitable deduction for the value of property and mineral rights in Alaska. The donor argued that the property, which he purchased for $30,000, had a value of $2.75 million as a luxu ...
Court Critical of Appraisals Based on Unreasonable Hypothetical Uses
The U.S. Court of Appeals for the Seventh Circuit rejected the donor's charitable deduction for the value of property and mineral rights in Alaska. The donor argued that the property, which he purchased for $30,000, had a value of $2.75 million as a luxu ...
Estate of Bessie I. Mueller v. CIR
The Tax Court rejected the estate's claim for equitable recoupment of taxes paid based on a valuation of the estate's stock. The estate reported the value of the stock to be $1,505 per share; however, 67 days after the valuation date it sold the stock fo ...
Main Event in Equitable Recoupment Defined as Overall Additional Tax
The Tax Court rejected the estate's claim for equitable recoupment of taxes paid based on a valuation of the estate's stock. The estate reported the value of the stock to be $1,505 per share; however, 67 days after the valuation date it sold the stock fo ...
IRS Contends License Payments 'a sham'
The ultimate issue in this case is whether taxable gifts or constructive dividend income were received by the son of the controlling shareholder of Home Shopping Network (HSN), through Pione ...
Tax Court Accepts Weighting of Market and DCF Methods
At issue is the value of a minority interest of 715,333 shares of Xilinx Inc., a manufacturer of programmable logic devices, as of the date of decedent's death, Oct. 22, 1989.
Thompson, L v. Commissioner
At issue is the valuation of the plaintiff's stock in harwood sawmill company for federal gift tax purposes.
McFarland v. Commissioner
At issue is whether the court must use a going concern methodology to value a 20-percent partnership interest held by the plaintiff at the time of her death.
Payment to Estate Partly for Decedent's Services
Decedent owned 71.43% of the stock of a law firm (CSB) that specialized in personal injury law, with earnings based on contingent fees.
Barudin v. Commissioner
At issue is the proper date-of-death value of decedent's ownership unit in a partnership that owned real property in New York City.
Estate of Freeman v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Scanlan v. Commissioner
At issue is the value of decedent's stock in Eatelcorp, Inc. on the date of his death and the date of a gift that was made approximately 3 months beforehand.
Thorough Update of Reports Essential
The Tax Court valued an undivided 50% interest in a closely held telecommunications company as of the 1991 valuation date. The court rejected the IRS' argument that a 1994 redemption of all non-Scanlan family stock was indicative of the 1991 fair market.
Speer v. Commissioner
At issue is the valuation of a software licensing company for federal income and gift tax purposes.
Discount From NAV Issue in Liquidating Trust Value
The issue is the value of a 5% interest in a liquidating trust. The only dispute is the appropriate discount from NAV.
Estate Tax Value Must Be Valued at Moment of Death
The sole issue in this case was whether a discount for restricted stock was appropriate when the restrictions that applied to the public stock during the decedent's lifetime became inapplicable by reason of the decedent's death.