Tax Court Clarifies Fair Market Value as a Standard of Value
The Tax Court clarified the definition of "fair market value" when it warned that the hypothetical sale should not be separated from the actual facts that would affect the value of the subject company's stock.
Estate of Gordon B. McLendon (McLendon I) v. Commissioner
The U.S .Court of Appeals for the Fifth Circuit concluded that the Tax Court erred when it valued interests in a partnership as partnership interests rather than assignee interests. It determined that state law established the objective criteria for trea ...
Texas Law Trumps Tax Court
The U.S .Court of Appeals for the 5th Circuit concluded that the Tax Court erred when it valued interests in a partnership as partnership interests rather than assignee interests.
Wheeler v. United States
At issue is the plaintiff's claim that the government refused to allow a 10% minority discount on the value of stock in the estate, and taxed the value of decendant's homestead.
10% Minority Discount Accepted
A magistrate for the U.S. District Court for the Western District of Texas recommended a minority discount in addition to a lack of marketability discount when valuing a 50% interest in a closely held corporation.
Wheeler v. United States
The executor of the estate brought this action to recover estate taxes paid on the decedent’s 50% interest in The Melton Co.
Estate of Clara K. Hoover v. CIR
The U.S. Court of Appeals for the Tenth Circuit concluded that for the purposes of applying the IRC sec. 2032A maximum valuation reduction, the value of the interest is to be calculated using fair market value inclusive of applicable minority and marketab ...
2032A Special Use Reduction Is in Addition to Minority and Marketability Discounts
The U.S. Court of Appeals for the 10nth Circuit concluded that, for the purposes of applying the IRC sec. 2032A maximum valuation reduction, the value of the interest is to be calculated using fair market value inclusive of applicable minority and marketability discounts.
'Safe Harbor Rate' Not Adequate to Present Value Note for Gift Taxes; Circuits Disagree on Issue
Taxpayer transferred assets in return for a promissory note bearing interest at the then current "safe harbor" interest rate, which was below the prevailing market rate.
Minority Share Gifts: Court Finds 30% Discount for Lack of Marketability
The parties stipulated to freely traded minority interest values, so the only issue was the discount for lack of marketability.
Schusterman v. United States
At issue is the taxpayers arguement that their use of the six percent safe harbor rate under I.R.C. 483 prevents the IRS from using the prevailing market interest rate to determine the dis ...
Estate of Lucile Marie McCormick v. CIR
The Tax Court valued interests in a real estate partnership. It accepted a valuation using the asset approach, plus various discounts. It rejected a discount for selling costs, and a discount for built-in capital gains taxes. It declined to aggregate the ...
Tax Court Reiterates Its Positions Regarding the Valuation of Real Estate Partnerships
The Tax Court valued interests in a real estate partnership.
Estate of McCormick v. Commissioner
One of the issues in this estate and gift tax case was the appropriate marketability discounts applicable to two partnership interests decedent owned on several different valuation dates (the dates of various gifts of the partnership interests).
Mandelbaum v. Commissioner
At issue is the amount of discount for lack of marketability that should be applied to determine the fair market value of certain shares of stock owned by some or all of petitioners.
Estate of Helen M. Trenchard v. CIR
The Tax Court concluded that gifts were made when the decedent formed a family corporation to which she transferred a family farm. Her child and grandchildren also contributed less valuable assets. In return for their contribution, the decedent received p ...
Tax Court Holds That a Portion of Contributions Made to a Family Farming Corporation Upon Its Formation Were Gifts to Younger Generations
The Tax Court concluded that gifts were made when the decedent formed a family corporation to which she transferred a family farm.
Estate of Ford v. Commissioner
At issue is the valuation of five closely held corporations of the in which Ray A. Ford held varying degrees of ownership on the date of his death.
Estate of Frank v. Commissioner
Issues are whether 91 shares of common stock are includable in decedent's gross estate pursuant to sections 2038(a)(1) and 2035(d)(2), and valuation of the stock.
Saltzman v. Commissioner
One of the issues was the fair market value of the family trusts' MBI stock at the time of the recapitalization.
Estate of Cervin v. Commissioner
In valuing 50% undivided interest in farm and homestead, Tax Court determines 20% discount should apply to each of decedent’s fractional interests.
Estate of Luton v. Commissioner
Issues are value of 78-percent interest in Rancho San Juan, Inc., one-third interest in Dune Lakes, Ltd., and 41.9-percent interest in the Miramonte Liquidating Trust, and penalties for und ...
Estate of Lauder v. Commissioner
Dispute regarding the fair market value of the stock in question centers on the effect of a shareholder agreement executed prior to Lauder's death.
Estate of Lauder v. Commissioner
The marketability discount issue involved the valuation of estate shares in a closely held family corporation, given a restrictive transfer of shares provision in the stockholder agreement.
Estate of Simpson v. Commissioner
At issue is the valuation of stock for gift tax purposes.