Tax Court Corrects Prior Valuation of LP Interest to Startling Result
On remand Tax Court recalculates decedent’s minority LP interest in family partnership by relying entirely on DCF value and giving no weight to value of company’s timberland assets; newly calculated value is half the original value.
Tax Court Corrects Prior Valuation of LP Interest to Startling Result
On remand Tax Court recalculates decedent’s minority LP interest in family partnership by relying entirely on DCF value and giving no weight to value of company’s timberland assets; newly calculated value is half the original value.
Estate of Giustina v. Commissioner (Giustina III)
On remand Tax Court recalculates decedent’s minority LP interest in family partnership by relying entirely on DCF value and giving no weight to value of company’s timberland assets; newly calculated value is half the original value.
9th Circuit Calls Tax Court Out Over ‘Imaginary Scenarios’
Ninth Circuit orders Tax Court to recalculate value of decedent’s minority interest in longtime family partnership owning timber assets because Tax Court accorded weight to NAV value based on “imaginary scenarios” that saw some possibility of liquidation.
Estate of Giustina v. Commissioner (II)
Ninth Circuit orders Tax Court to recalculate value of decedent’s minority interest in longtime family partnership owning timber assets because Tax Court accorded weight to NAV value based on “imaginary scenarios” that saw some possibility of liquidation.
Court Pans Valuation Based on Expert’s Fiction, Not Fact
High court rejects valuation of husband’s interest in closely held company where wife’s expert transformed it from one owned by four people into one managed by one person to increase its overall value.
Ward v. Ward
High court rejects valuation of husband’s interest in closely held company where wife’s expert transformed it from one owned by four people into one managed by one person to increase its overall value.
Tax Court Rejects GPCM, Dissects DCF in Valuing Minority LP Interest
Tax Court calculates value of a 41% family limited partnership (timberland assets) using a net asset value and DCF approach, the latter including a 25% DLOM and 16% discount rate, adjusted for unique risks.
Estate of Giustina v. Commissioner (I)
Tax Court calculates value of a 41% family limited partnership (timberland assets) using a net asset value and DCF approach, the latter including a 25% DLOM and 16% discount rate, adjusted for unique risks.
Lack of Present Economic Benefit Results in Finding of Future Interest
In the April 2002 issue of Shannon Pratt's Business Valuation Update, Owen Fiore and Erin Wilms discussed various attacks by the IRS on pass-through entities.
11th Circuit Affirms Shepherd v. Commissioner
This gift tax case is an appeal from the Tax Court's December 2000 decision, which was abstracted in the December 2000 issue of Shannon Pratt's Business Valuation Update®, at page 5.
Hackl v. Commissioner (I)
The issue was whether the gifts were present interests or future interests under Section 2503(b) of the tax code.
Gifts of Future Interest Do Not Qualify for Sec. 2503(b) Exclusion
The full Tax Court considered whether gifted LLC units subject to a restrictive operating agreement were gifts of a present or future interest in the gifted property for the purposes of the annual gift tax exclusion.
Shepherd v. Commissioner (II)
Issues were characterization of ifts as indirect gifts and proper application of stipulated combined minority and marketability discount.
Tax Court Adopts 60% Fractional Interest Discount
This estates of John and Sarah Baird were consolidated for this proceeding.
Estate of Baird v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Holding Company Valued Using Asset Method; Small Marketability Discount Applied
The primary issue in this estate tax matter was the fair market value of decedent's 98% stock interest in Johnco Inc., a holding company with timberland as its principal asset.
Estate of Jameson v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Court Decides 44% Total Discount on Undivided Real Estate Parcels
The Tax Court decision in the case of Estate of Ellie B. Williams adds to the body of law on the valuation of undivided real estate interests.
Estate of Williams v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
In re Marriage of Wilson
At issue is the valuation of husband's partnership interest in a timber business .