Neonatology Associates v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Linda Karen Brownlow Craven v. U.S.A.
The U.S. Court of Appeals for the Ninth Circuit concluded that a redemption of a former spouse's interest in the parties' business by the corporation pursuant to a divorce instrument, which left the other spouse in control of the corporation, met the requ ...
Corporate Stock Redemption Qualifies for §1041 No Recognition Treatment
The U.S. Court of Appeals for the 9th Circuit concluded that a redemption of a former spouse's interest in the parties' business by the corporation pursuant to a divorce instrument, which left the other spouse in control of the corporation, met the requ ...
IPO Price Assists in Determining Fair Market Value of Stock
The issue in this income tax matter is the fair market value of stock of Wedtech Corp. received by petitioner Mario Biaggi, but not reported as income on his 1983 income tax return.
Jean A. Stanko (Stanko II) v. CIR
The U.S Court of Appeals for the Eighth Circuit reversed the Tax Court's valuation of a note which was fraudulently transferred from a husband to his wife. The Eighth Circuit determined that the deferred capital gains taxes on the note should have been co ...
Deferred Capital Gains Taxes Paid Must Be Considered
The U.S Court of Appeals for the 8th Circuit reversed the Tax Court's valuation of a note that was fraudulently transferred from a husband to his wife.
Normandie Metal Fabricators, Inc. v. CIR
The Tax Court applied the hypothical invetsor test to determine whether the compensation a corporation paid to its controlling shareholders was reasonable. It considered the mulit-factor test from a reasonable investor's point of view. In doing so, the c ...
Hypothetical Investor Test Used to Determine Officers’ Reasonable Compensation
The Tax Court applied the hypothical invetsor test to determine whether the compensation a corporation paid to its controlling shareholders was reasonable.
Gow v. Commissioner (I)
At issue is the value of shares of stock of Williamsburg Vacations, Inc., awarded to the plaintiff.
Tax Court Values Bonus Compensation Stock, Applies Two-Tier Discounts
The valuation issue in this case pertained to the fair market value of two minority blocks of stock of Williamsburg Vacations Inc. (WVI) issued as bonus compensation to a shareholder/officer/director of a C corporation investment holding company in early 1989 and 1990.
Mary K. Heckaman v. CIR
The U.S. Tax Court determined that payments a husband made to his former spouse under a provisional order constituted taxable alimony under IRC sec. 71 and IRC sec. 215. The provisional order did not contain a death contingency. Thus, the court looked to ...
Death Contingency Considered
The U.S. Tax Court determined that payments a husband made to his former spouse under a provisional order constituted taxable alimony under IRC sec. 71 and IRC sec. 215.
Biaggi v. Commissioner
At issue is the fair market value of petitioners shares of stock in Wedtech Corp. for federal tax purposes.
Carol M. Read, et al. v. CIR
The full Tax Court considered whether a corporate redemption of a former spouse's stock in the parties' business pursuant to a divorce qualified for nonrecognition treatment under IRC sec. 1041. The Tax Court specifically considered the legal standard to ...
Sec. 1041 Nonrecognition Warranted in Company’s Redemption of Stock
The full Tax Court considered whether a corporate redemption of a former spouse's stock in the parties' business pursuant to a divorce qualified for nonrecognition treatment under IRC sec. 1041.
Exacto Spring v. Commissioner
At issue is the interpretation of tax law that allows a business to deduct from its income its "ordinary and necessary" business expenses.
7th Circuit Rejects Tax Court's Reasonable Compensation Test
The issue in this corporate income tax matter was whether the petitioner's deduction for the salary of its chief executive and principal owner was excessive, as asserted by the IRS.
7th Circuit Affirms Independent Investor Test When Determining Reasonable Compensation
The 7th Circuit reversed the U.S. Tax Court and determined that the independent investor test was the appropriate test for determining whether an executive's compensation was reasonable and, thus, deductible to the corporation under IRC sec. 162.
7th Circuit Affirms Independent Investor Test When Determining Reasonable Compensation
The 7th Circuit reversed the U.S. Tax Court and determined that the independent investor test was the appropriate test for determining whether an executive's compensation was reasonable and, thus, deductible to the corporation under IRC sec. 162.
BTR Dunlop Holdings, et al. v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Potential Earnings and Synergies Relevant in Determining Fair Market Value of Transferred Subsidiary
The issue in this corporate income tax matter is the fair market value, for purposes of IRC §§ 311(b) and 482, of Schlegel UK Holdings Ltd. and Schlegel GmbH, which were transferred from the taxpayer, BTR Dunlop Holding, Inc., to the taxpayer's parent corporation, BTR, Plc.
Venture Funding, Ltd. v. Commissioner of Internal Revenue
At issue is the deduction for the business expense of compensation for personal services by Venture Funding.
Venture Funding, Ltd. v. Commissioner
The U.S. Court of Appeals for the 6th Circuit affirmed the Tax Court's ruling that petitioner was not entitled to a deduction under 26 U.S.C. § 83 equal to the value of stock transferred to its employees.
Dudley B. Merkel, et al. v. CIR
A divided Ninth Circuit affirmed the Tax Court's decision, finding that a contingent obligation to pay is not a liability for insolvency purposes under the Tax Code (IRC sec. 108). The taxpayer excluded an amount of discharge of indebtedness income receiv ...
Addressing Contingent Liabilities in Insolvency Situations Under the Tax Code
A divided 9th Circuit affirmed the Tax Court's decision, finding that a contingent obligation to pay is not a liability for insolvency purposes under the Tax Code (IRC sec. 108).