Tax Court Favors IRS’s Cost Markup Analysis to Compute Management Fee
In a suit over fees paid by taxpayers’ operating companies to taxpayer-controlled management company, Tax Court says IRS expert’s cost markup analysis produces most credible arm’s-length management fee; this fee represents the allowable deduction amount.
Wycoff v. Commissioner
In a suit over fees paid by taxpayers’ operating companies to taxpayer-controlled management company, Tax Court says IRS expert’s cost markup analysis produces most credible arm’s-length management fee; this fee represents the allowable deduction amount.
Appellate Court Reverses Trial Court’s Decision Because Findings Were Based on Old Valuation
The trial court held that husband's marital interest in Garman Co. Inc. consisted of his marital shares in Garman valued at $40,550, plus the additional contribution of husband's share of the retained earnings reinvested in the company during the marriage, $171,467.
Craig-Garner v. Garner
The appellate court reversed the trial court's valuation because it had based its findings on an outdated valuation report.