Utah Resources International, Inc. v. Mark Technologies Corp.
State’s high court strikes down district court’s fair value determination, finding reliance on prior law prohibiting use of deductions was misguided where company pursued strategy of selling off real estate and other assets at time of triggering event.
Cullifer v. Commissioner
In transferee liability case, Tax Court finds IRS proved petitioner was liable for causing company’s fraudulent asset transfers and benefitted from intermediary company’s fraudulent transfer; valuations showed company was insolvent at time of transfers.
Ignoring Accountant’s Advice, Taxpayers Botch Investment Strategy
Tax Court finds taxpayers engaged in “prohibited transactions” under IRC Section 4975(c(1)(B) when making personal guaranties on a promissory note to a company they had bought via IRAs for purposes of deferring until retirement any income tax liability on ...
Peek v. Commissioner
Tax Court finds taxpayers engaged in “prohibited transactions” under IRC Section 4975(c(1)(B) when making personal guaranties on a promissory note to a company they had bought via IRAs for purposes of deferring until retirement any income tax liability on ...
Tax Court Accepts Negative Industry Risk Premium and Unique Combined Discount Matrix
The decedent, Helen Deputy, formed a family limited partnership comprised of 99% of a limited partnership interest retained by Deputy and two 0.5% general partnership interests, one held by Deputy and one held by her son.
Estate of Deputy v. Commissioner
Issue was the fair market value of a 19.99% interest of stock owned by an FLP, and court discussed negative industry risk premium and unique matrix for determining marketability discount.
1999 in review: What we learned in a busy year
My 30 th year in the business valuation profession ( see December 1999 BVU , p.1) was an active one in terms of development in the profession. Here are some of the highlights: l 1999 was o ...
Court Disallows Built-In Capital Gains Discount
At issue is whether the estate of Welch is entitled to discount the value of stock for built-in capital gains taxes, causing a deficiency of $59,987 in federal estate taxes.
Estate of Welch v. Commissioner (I)
At issue is whether the estate of Welch is entitled to discount the value of stock for built-in capital gains taxes.