Estate of Rodgers v. Commissioner of Internal Revenue
At issue is is the fair market value of the interest that Lynn M. Rodgers (decedent) owned on the date of his death in Marrero Land and Improvement Association, Limited.
Absorption Discount Applied to Value Assets
The issue in this estate tax matter is the valuation of decedent's 166 2/3 shares of stock representing one-third of the total of Marrero Land, a real estate operating company that engages in "the business of acquiring, developing, managing, improving, maintaining, leasing, and selling real estate."
Effective Date of Critical to Valuation of Stock
This case involves a claim by the Commissioner that taxpayer is liable for income tax on the difference between the price paid for stock and its fair market value under § 83(a) of the Internal Revenue Code.
Theophilos v. Commissioner
Issue was whether the property received by the taxpayer was stock aquired in a closely held company or the contract to acquire the stock at a later time.
Theophilos v. Commissioner
At issue in this case was whether the taxpayer acquired a beneficial interest in the closely held corporation of his former employer and whether full value was paid for the 40% minority interest in nonvoting common stock.