Gift Tax Case Pivots on Key Assumption Informing Valuations
Taxpayer parents incurred gift tax liability when, based on improper valuations, they agreed to merge their S corp. with their sons’ S corp. and accepted an unduly low interest in the new company while sons received an unduly high interest, Tax Court says ...
Estate Valuation Can’t Ignore Historical Data, Tax Court Says
Tax court disapproves of estate’s “conflicting expert reports” as to value of decedent’s 100% interest in a C corp. but ultimately adopts estate’s DCF valuation, finding its treatment of personal goodwill is more credible than the IRS’s approach.
Cavallaro v. Commissioner
Taxpayer parents incurred gift tax liability when, based on improper valuations, they agreed to merge their S corp. with their sons’ S corp. and accepted an unduly low interest in the new company while sons received an unduly high interest, Tax Court says ...
Estate of Adell v. Commissioner
Tax court disapproves of estate’s “conflicting expert reports” as to value of decedent’s 100% interest in a C corp. but ultimately adopts estate’s DCF valuation, finding its treatment of personal goodwill is more credible than the IRS’s approach.
Tax Ct. How-to of Valuing Holding Company, Avoiding Accuracy Penalty
Tax Court favors net-asset-value over capitalized-dividend approach for FMV determination of interest in holding company with marketable securities because NAV starts out on “firm ground” with stock prices one can look up whereas income approach relies en ...
Estate of Richmond
Tax Court favors net-asset-value over capitalized-dividend approach for FMV determination of interest in holding company with marketable securities because NAV starts out on “firm ground” with stock prices one can look up whereas income approach relies en ...
Court Rejects Expert’s Regression Equation to Determine DLOM
In determining the fair market value of a revocable trust’s interest in an LLC, the Tax Court adopts the IRS expert’s marketability discount and valuation; he rightly assumed it was reasonably foreseeable at the time of the decedent’s death that the trust ...
Estate of Koons v. Commissioner
In determining the fair market value of a revocable trust’s interest in an LLC, the Tax Court adopts the IRS expert’s marketability discount and valuation; he rightly assumed it was reasonably foreseeable at the time of the decedent’s death that the trust ...