The U.S. Court of Appeals for the Fifth Circuit determined that the Tax Court erroneously valued the assets of a non-profit corporation that converted to a for profit corporation and rendered a decision for the taxpayer.
The issue in this consolidated case involving the Caracci family was whether the value of the Sta-Home Health Agency Inc. (SHHA) and related entities transferred into S corporations exceeded the consideration paid.
The issue was whether the value of the Sta-Home Health Agency, Inc. (SHHA) and related entities transferred into S corporations exceeded the consideration paid.
This case deals with the valuation for estate tax purposes of four Housing and Urban Development (HUD) housing partnerships and one real estate management partnership.
At issue in the equitable distribution litigation was the value of Fred Jr.'s 50-percent general partnership interest in the partnerships.
One of the issues was the valuation of stock in a closely-held nursing home business at $0 despite testimony from both parties to the contrary.