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37% Discount Denied in Poorly Executed FLP

Court denies discount for family limited partnership in estate tax case where FLP made funds available to decedent and failed to observe partnership formalities and legitimate business.

Estate of Jelke v. Commissioner (II)

Eleventh Circuit rejects Jelke and adopts dollar-for-dollar discount for contingent capital gains tax liability.

IRS Burden of Proof Does Not Obviate Errors in Taxpayer Valuation

2nd Circuit rejects taxpayer’s contention that, should IRS fail its burden of proof, then the court must defer to estate’s valuation analysis.

Parties Unable to Settle Discount for Fractional Interest in Artwork

Finding that the estate failed to carry its burden to prove support for 35% discount in fractional (50%) interest in art, the court confirms IRS 5% discount.

Estate of Bigelow v. Commissioner (II)

Court denies discount for family limited partnership in estate tax case where FLP made funds available to decedent and failed to observe partnership formalities and legitimate business.

Two New Lottery Cases: The Odds of Discounting From Annuity Tables Decrease

6th Circuit finds that government annuity tables do not accurately reflect fair market value of lottery payments and continues case for expert evidence.

Do BV Methods Apply to Determining Discount for Fractional Interest in Art?

Court considers limits to business valuation “science” for determination of discounted value of fractional interest in art.

Estate of Thompson v. Commissioner (II)

Second Circuit rejects taxpayer’s contention that should IRS fail its burden of proof, then the court must defer to estate’s valuation analysis.

Litman v. United States

Federal Court of Claims prefers option-pricing models to quantify marketability discounts for large block of restricted Internet stock.

Stone v. United States

Finding that the estate failed to carry its burden to prove support for 35% discount in fractional (50%) interest in art, the Court confirms IRS 5% discount.

Two Cases Question FLPs as Estate Planning/Asset Protection Devices

IRS allowed 33% combined discount for FLP—but court rules that state (Pennsylvania) Department of Revenue does not have to defer to IRS calculations to disallow discount.

Estate of Cyril Magnin v. Commissioner (II)

*This Memorandum Opinion supplements our Memorandum Opinion in Estate of Magnin v. Commissioner, T.C. Memo. 1996-25, revd. and remanded 184 F.3d 1074 (9th Cir. 1999). T.C. Memo. 2001-31 UNITED STATES TAX COURT ESTATE OF CYRIL I. MAGNIN, DECEASED, DONALD ISAAC MAGNIN, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 24883-92. Filed February 12, 2001. Stuart S. Lipton, Frederick J. Adam, Jerome B. Falk, Jr., Douglas A. Winthrop, and Denise M. Riley, for ...

Davis v. United States

Second Circuit finds that although IRC annuity tables do not account for lack of marketability of lottery payments, the discount is not so substantial as to warrant departure therefrom.

Valuation Discounts Not Permitted in Light of Possible Section 691 (c) Deduction

The IRS denied discounts for potential income tax and lack of marketability in determining the value of the estate’s several IRAs.

Negron v. United States (I)

Sixth Circuit finds that government annuity tables do not accurately reflect fair market value of lottery payments, and continues case for expert evidence.

Stone v. U.S. (I)

Court considers limits to business valuation “science” for determination of discounted value of fractional interest in art.

In re Estate of Berry

IRS allowed 33% combined discount for FLP—but Court rules that state (Penn.) Department of Revenue does not have to defer to IRS calculations to disallow discount.

Tax Court Determines Methodology, Discounts for Large Block of Public Shares

Tax Court decides appropriate valuation methodology and discounts for a large block (13%) of publicly traded, restricted shares.

Another FLP Deduction Disallowed for Lack of Viable Business Purpose

Tax Court includes asset of family limited partnership (FLP) in estate, as FLP had no legitimate business purpose, other than tax avoidance.

Estate of Gimbel v. Commissioner of Internal Revenue

Tax Court decides appropriate valuation methodology and discounts for a large block (13%) of publicly traded, restricted shares.

Estate of Korby v. Commissioner of Internal Revenue

Tax Court includes asset of Family Limited Partnership (FLP) in estate, as FLP had no legitimate business purpose, other than tax avoidance.

Reasonable Compensation Analysis Rejected for Lack of Reasonable Comparables

Court rejects reasonable compensation analysis for lack of reasonable comparables to broker/dealer in convertible securities.

Tax Court Declines to Tax Affect S Corp in Gift Transfer Case

In a post-Gross decision, the Tax Court considers tax affecting S corp earnings and also discounts for lack of marketability and control.

Patricia A. Schade v. Jack E. Gethman

The Iowa Court of Appeals adopted the independent expert’s opinion as to the officer’s compensation over the corporate accountant’s opinion in this trust accounting matter. It based its decision as to officer compensation on consideration of the different ...

Reasonable Compensation for Officer of Real Estate Business

The Iowa Court of Appeals adopted the independent expert’s opinion as to the officer’s compensation over the corporate accountant’s opinion in this trust accounting matter.

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