*This Memorandum Opinion supplements our Memorandum Opinion in Estate of Magnin v. Commissioner, T.C. Memo. 1996-25, revd. and remanded 184 F.3d 1074 (9th Cir. 1999). T.C. Memo. 2001-31 UNITED STATES TAX COURT ESTATE OF CYRIL I. MAGNIN, DECEASED, DONALD ISAAC MAGNIN, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 24883-92. Filed February 12, 2001. Stuart S. Lipton, Frederick J. Adam, Jerome B. Falk, Jr., Douglas A. Winthrop, and Denise M. Riley, for ...
California court of appeals considers whether lost profits can be based on the short operating history of an relatively new business.
The 8th Circuit Court of Appeals affirmed the lower court’s award of business interruption losses in this vexatious refusal to pay case.
This case involves a hearing on remand from the 9th Circuit to provide sufficient analysis of the consideration value of common and preferred stock in two closely held companies transferred and received by Cyril Magnin, the life estate holder.
The Tax Court clarified the definition of 'Fair Market Value' when it warned that the hypothetical sale should not be separated from the actual facts that would affect the value of the subject company's stock.
The Tax Court clarified the definition of "fair market value" when it warned that the hypothetical sale should not be separated from the actual facts that would affect the value of the subject company's stock.
The parties stipulated to freely traded minority interest values, so the only issue was the discount for lack of marketability.
At issue is the amount of discount for lack of marketability that should be applied to determine the fair market value of certain shares of stock owned by some or all of petitioners.
One issue in this case was the valuation of a retail clothing business.