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9th Circuit Follows Up on Value of Fractional Interest in Major Art Collection

9th Circuit rejects estate’s appeal of 5% discount for a 50% undivided fractional interest in art collection, based on insufficient appraisal evidence to carry the taxpayer’s burden of proof to show that IRS assessment was wrong.

Heckerman v. Commissioner

Court finds $2.5 million cash transfers to family limited company are indirect gifts, subject to gift tax for full value, excluding 58% marketability discounts.

Tax Court’s Adjustment to Reasonable Compensation ‘Dizzying and Arbitrary’

7th Circuit reverses Tax Court’s determination of reasonable compensation for CEO of third largest retail hardware chain, questioning its reliance on investor rate of return as the sole driver of a decision.

Terrible FLP Facts Preclude Analysis of Discounts

Tax Court finds not one factor supporting a legitimate, nontax business purpose for family limited partnerships funded with over $2 million in largely untraded marketable securities.

Estate of Miller v. Commissioner

Court finds initial transfer of funds to FLP qualifies for exclusion from the estate at discounted value, but second transfer does not, for lack of bona fide business purpose.

New Tax Court Decision on Discounts and Embedded Taxes Hinges on Experts

Tax Court considers determination of discounts for embedded capital gains taxes, lack of control, and lack of marketability for estate’s interests in two closely held companies, one owning primarily farm land and the other marketable securities.

Lottery Case and Effect of Transfer Restrictions on Valuing Annuities

6th Circuit joins majority of federal courts in finding that IRS annuity tables are appropriate when valuing nonassignable lottery payments for estate tax purposes.

Estate of Jorgensen v. Commissioner

Tax Court finds not one factor supporting a legitimate, nontax business purpose for family limited partnerships funded with over $2 million in largely untraded marketable securities.

Stone v. U.S. (II)

Ninth Circuit rejects estate’s appeal of 5% discount for a 50% undivided fractional interest in art collection, based on insufficient appraisal evidence to carry the taxpayer’s burden of proof to show that IRS assessment was wrong.

Menard v. Commissioner (II)

Seventh Circuit reverses Tax Court’s determination of reasonable compensation for CEO of third largest retail hardware chain, questioning its reliance on investor rate of return as the sole driver of a decision, and rejecting its comparison to comparable ...

Estate of Litchfield v. Commissioner

Tax Court considers determination of discounts for embedded capital gains taxes, lack of control, and lack of marketability for estate’s interests in two closely held companies, one owning primarily farm land and the other marketable securities.

Negron v. United States (II)

Sixth Circuit joins majority of federal courts in finding that IRS annuity tables are appropriate when valuing non-assignable lottery payments for estate tax purposes.

Tax Court Examines Charitable Deduction

Tax Court denies charitable deductions for donation of intangible goodwill from taxpayers’ medical practices to newly formed healthcare corporation.

IRS and Taxpayer Agree to 35% DLOM—If FLP Transfers Pass ‘Indirect Gift’ Tests

Tax Court accepts stipulated 35% DLOM after finding that FLP funding and transfer is not an indirect gift.

Federal Court Issues New Rule for Valuing Stock in Insurance Demutualization

Federal Claims Court rules against long-standing IRS position that stock in insurance company demutualization has a cost basis of zero value.

Bianca Gross v. Commissioner

Tax Court accepts stipulated 35% DLOM after finding that FLP funding and transfer is not an indirect gift.

Tax Court Rejects Appraisal of Donated Stock for Incorrect Premise of Value

Tax Court approves 64% combined discounts (advocated by IRS) for valuing medical service corporation slated for conversion to a nonprofit.

Fisher v. U.S.

Federal Claims Court rules against long-standing IRS position that stock in insurance company demutualization has a cost-basis of zero value.

Bergquist v. Commissioner of Internal Revenue

Tax Court approves 64% combined discounts (advocated by IRS) for valuing medical service corporation slated for conversion to a non-profit.

Derby v. Commissioner

Tax Court denies charitable deductions for donation of intangible goodwill from taxpayers’ medical practices to newly formed healthcare corporation.

Reasonable Compensation Does Not Consider CEO’s Role in Related Businesses

Tax Court disallows $500,000 bonus to CEO of startup as reasonable compensation, despite company enjoying a 42% return on equity.

Universal Marketing, Inc. v. Commissioner

Tax Court disallows $500,000 bonus to CEO of start-up as reasonable compensation, despite company enjoying a 42% return on equity.

Litman v. United States

Federal claims court rejects IRS and others’ reliance on restricted stock studies to determine appropriate discount for lack of marketability for restricted stock, preferring taxpayer’s option-pricing and CAPM analysis.

IRS Stumbles on Characterization and Valuation of Stock Warrants

Stock warrants issued as part of settlement agreement are not compensation and are taxable at grant date if they have an ascertainable fair market value.

Kimberlin v. Commissioner

Stock warrants issued as part of settlement agreement are not compensation, and are taxable at grant date, if they have an ascertainable fair market value.

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