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Tax Court Allows for ‘Slight’ Discount for Lack of Control for Majority Interests in Real Estate Holding Companies

In a gift and estate tax dispute, the estate and Internal Revenue Service agreed to apply discounts for lack of control and marketability to the majority interests in a number of real estate holding companies. The U.S. Tax Court noted that, in prior decisions, the court found no discount for lack of control applied. However, given the parties’ agreement, here, the court said it would apply a “slight” or “low” discount.

Estate of Warne v. Commissioner

In a gift and estate tax dispute, the estate and Internal Revenue Service agreed to apply discounts for lack of control and marketability to the majority interests in a number of real estate holding companies. The U.S. Tax Court noted that, in prior decisions, the court found no discount for lack of control applied. However, given the parties’ agreement, here, the court said it would apply a “slight” or “low” discount.

D.C. Circuit Upholds Remainder-Interest Valuation in Weird Charitable Contribution Case

In charitable contribution case involving remainder interest, D.C. Circuit upholds Tax Court’s value-related findings, including that petitioner did not provide qualified appraisal and did not meet substantiation requirements; valuation here is to be based on FMV, not actuarial tables.

Blau v. Commissioner (RERI II)

In charitable contribution case involving remainder interest, D.C. Circuit upholds Tax Court’s value-related findings, including that petitioner did not provide qualified appraisal and did not meet substantiation requirements; valuation here is to be based on FMV, not actuarial tables.

Tax Court Introduces Formula to Value Donated Remainder Interest

Tax Court rules for IRS in disallowing deduction for charitable contribution involving remainder interest in leased property; requisite appraisal summary omits vital information, and court’s valuation formula shows donor made gross valuation misstatement.

Tax Court Introduces Formula to Value Donated Remainder Interest

Tax Court rules for IRS in disallowing deduction for charitable contribution involving remainder interest in leased property; requisite appraisal summary omits vital information, and court’s valuation formula shows donor made gross valuation misstatement.

RERI Holdings I, LLC v. Commissioner (RERI I)

Tax Court rules for IRS in disallowing deduction for charitable contribution involving remainder interest in leased property; requisite appraisal summary omits vital information, and court’s valuation formula shows donor made gross valuation misstatement.

RERI Holdings I, LLC v. Comm’r

Tax Court denies IRS’s summary judgment motion to disallow claimed charitable deduction arguing taxpayer’s appraiser improperly valued donated interest in LLC using present-value Section 7520 tables and failed to submit “qualified appraisal.”

Tax Court Foils ‘End Run’ Around Expert Rules

Tax Court rejects taxpayer’s attempt to place in evidence a new appraisal regarding the decedent’s interest in an LLC whose principal asset was real estate by way of stipulation, finding he failed to qualify the appraiser as an expert and did not present ...

Estate of Tanenblatt v. Commissioner

Tax Court rejects taxpayer’s attempt to place in evidence a new appraisal regarding the decedent’s interest in an LLC whose principal asset was real estate by way of stipulation, finding he failed to qualify the appraiser as an expert and did not present ...

IRS Gives Hybrid Business Favorable Tax Status

In a non-precedential ruling, the IRS approves a proposed data center business for status as a real estate investment trust (REIT) under IRC section 856, finding the properties the company plans to lease to tenants are real property and constitute real es ...

Private Letter Ruling 201314002

In a non-precedential ruling, the IRS approves a proposed data center business for status as a real estate investment trust (REIT) under IRC section 856, finding the properties the company plans to lease to tenants are real property and constitute real es ...

Discounts in Estate Tax Valuation Do Not Apply in Divorce

Appraisal used in estate tax valuation, which included substantial discounts for lack of marketability and control, were inappropriate for use ten years later in divorce.

Short v. Short

Appraisal used in estate tax valuation, which included substantial discounts for lack of marketability and control, were inappropriate for use 10 years later in divorce.

Estate of Mitchell v. Commissioner

Tax Court sides with estate and holds proper method for valuing 100% leased-fee interests of real property is income capitalization method, rather than lease buyout method proposed by respondent’s expert.

May Buy-Sell Appraiser Modify an Opinion After Submitting a Report?

Trial court holds that an appraiser who submits a second report to correct for errors, omissions in the original is nevertheless “bound” by the original appraisal.

Chapman v. The Westerner

Trial court holds that an appraiser who submits a second report to correct for errors, omissions in the original is nevertheless “bound” by the original appraisal.

City of Palm Springs v Miller

The City of Palm Springs (the “City”) brought a condemnation action against landowners to acquire property for a project to expand the operating capabilities of the City’s regional airport. Ronald Miller (“Miller”) is one of those landowners. The only ...

Fair Value in Shareholder Dissent Warrants Minority Discount

Minority discount applies to statutory fair value valuation of minority owner’s stock, where no evidence of wrongful conduct by corporation.

Hall v. Glenn’s Ferry Grazing Assoc.

Minority discount applies to statutory fair value valuation of minority owner’s stock, where no evidence of wrongful conduct by corporation.

HRFH, Inc. v. Pourlos Enterprises, Inc.

The South Carolina Court of Appeals affirmed the exclusion of testimony on damages from the owner of a new business.

Message Center Management, Inc. v. Shell Oil Products Company

The Connecticut Court of Appeals reversed the trial court’s decision to exclude testimony from a director of the plaintiff, which was the basis for the jury award, on reconsideration and reduced the damage award to $1.

Arthur Reardon v. Lovely Development, Inc.

The Supreme Court of Maine reversed a jury’s lost profits award in this conversion case because the award was not supported by evidence in the record.

Norbert Delacey v. Martha Delacey

The Arkansas Court of Appeals considered whether the trial court erred in valuing and equitably distributing minority interests in two businesses. The interests were subject to an agreement that required the owner to tender the interests back to the compa ...

Business Interests Are Marital Property Subject to Valuation and Distribution

The Arkansas Court of Appeals considered whether the trial court erred in valuing and equitably distributing minority interests in two businesses.

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