DCF Model Proves Unreliable Tool for Ascertaining Cost Basis
Court finds numerous problematic assumptions make plaintiff expert’s DCF model unreliable indicator of FMV of thrift’s branching right; without this value, plaintiff is unable to establish the right’s cost basis and support its tax refund claim.
Washington Mutual, Inc. v. United States
Court finds numerous problematic assumptions make plaintiff expert’s DCF model unreliable indicator of FMV of thrift’s branching right; without this value, plaintiff is unable to establish the right’s cost basis and support its tax refund claim.
Book Value, Not Market Value, Determines Essential Reliance Damages
In this extensive case, one of the myriad issues was whether Transcapital Financial Corporation’s essential reliance interest should be determined by book value or market value.
American Capital Corporation v. United States
In this extensive case arising from the enactment of the Financial Institutions Reform, Recovery, and Enforcement Act, Pub. L. No. 101-73, 103 Stat. 183 (1989) (FIRREA) in response to the savings and loan crisis of the 80's, involving a breach of contract ...
Savings Bank Wins a Few, Loses a few Under a Slough of Damages Theories
On Sept. 5, 2002, the court issued a liability opinion holding that the United States, through the enactment of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA), had breached an express contract with Franklin Federal Savings Bank to treat its supervisory goodwill as a regulatory capital asset amortizable over 25 years.
Franklin Federal Savings Bank v. United States
At issue are claims of damages by the plaintiffs.
Charitable deduction disallowed where stock not publicly traded
The only issue in this case was whether the petitioner (John C. Todd), who formed the Todd Family Foundation (Foundation), a nonprofit corporation, was entitled to charitable deductions.
Todd v. Commissioner
The only issue in this case was whether the petitioner, who formed a nonprofit corporation, was entitled to charitable deductions.
Court Rejects Inadequate DCF; Selection of Comparables Critical 30% Lack of Marketability Discount for Controlling Interest
The issue in this estate tax case was the fair market value of decedent's 1,499 shares of Peoples Trust and Savings Bank of Boonville, Ind., constituting 49.97% of the 3,000 shares outstanding.
Estate of Hendrickson v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Court Rejects Inadequate DCF; Selection of Comparables Critical
The issue in this estate tax case was the fair market value of decedent's 1,499 shares of Peoples Trust and Savings Bank of Boonville, Ind., constituting 49.97% of the 3,000 shares outstanding.
Appropriate Consideration of Comparable Companies Necessary When Using the Public Guideline Company Approach
The Tax Court considered the valuation of a single-location commercial bank that acted like a thrift.
Estate of Branson v. Commissioner of Internal Revenue
At issue is the fair market value of decendent's stock acquisitions.
Backlog of Willing Buyers Offsets Marketability Discount
The primary issue in this estate tax matter is the fair market value of 12,889 shares of Savings Bank of Mendocino County (Savings) stock, and 500 shares of Bank of Willits (Willits) stock, owned by decedent on the date of his death.
Bedessem v. Bedessem
At issue is the calculation of husband's earning capacity based upon his stock ownership.
Potential return on stock improper basis for imputing income
The trial court increased husband's maintenance obligation to his former wife based upon additional income that was imputed to him. Husband appealed. The Court of Appeals reversed and remand ...
Ahmanson Foundation v. United States
Issues include valuation of assets in the gross estate, propriety of a charitable deduction, and valuation of property giving rise to a charitable deduction if held allowable.