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Tax Court Adopts Substantial Discount for Embedded Capital Gains But Declines Per se Rule

Tax Court adopts the taxpayer’s dollar-for-dollar discount for embedded capital gains tax liability based on 2nd Circuit precedent and its own present-value analysis but specifically declines to adopt the per se rule of the 5th and 11th Circuits.

Estate of Jensen v. Commissioner

Tax Court adopts the taxpayer’s dollar-for-dollar discount for embedded capital gains tax liability based on 2nd Circuit precedent and its own present-value analysis, but specifically declines to adopt the per se rule of the 5th and 11th Circuits.

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