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Structure, Valuation & Tax Insights for Logistics & Trucking Companies

Join Jaclyn Burket Frank and Ricky Castillo for an engaging trip into the world of logistics and trucking businesses. Discover the different types of entity structure along with the advantages and disadvantages of each structure. Learn how the 2018 tax law impacted each entity structure and common deductible/nondeductible expenses for the logistics and trucking industry. The industry-specific adjustments to consider along with specific questions to ask business owners to determine whether economic, governmental, and location ...

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.

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.

BVU News and Trends November 2018

A monthly roundup of key developments of interest to business valuation experts.

Can ESOP Appraisal Satisfy Charitable Contribution Reporting Requirement?

Court finds using ESOP appraisal to show “qualified appraisal” is a long shot to meet charitable contribution verification requirements because appraisal did not consider tax consequences or value shares individual petitioners donated, but petitioners may have reasonable cause defense.

Chrem v. Commissioner

Court finds using ESOP appraisal to show “qualified appraisal” is a long shot to meet charitable contribution verification requirements because appraisal did not consider tax consequences or value shares individual petitioners donated, but petitioners may have reasonable cause defense.

Valuation of private company stock for donations

Chris Mellen (Valuation Research Corp.) reports a marked increase in demand for valuations of shares of privately held companies before an M&A transaction in connection with a charitable gift.

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.

Manipulation of Valuation of Bequeathed Stock Sinks Charitable Contribution Claim

Tax Court says executor of estate in series of post-death measures changed the value and size of decedent’s stock donation and may not claim date-of-death value of assets not actually transferred to family foundation; court affirms estate tax deficiency.

Estate of Dieringer v. Commissioner

Tax Court says executor of estate in series of post-death measures changed the value and size of decedent’s stock donation and may not claim date-of-death value of assets not actually transferred to family foundation; court affirms estate tax deficiency.

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.”

Valuing a Hypothetical Asset Renders Appraisal ‘Meaningless’

Tax Court says petitioner failed IRC’s section 170 requirements for charitable contribution deduction because his claim leaned on appraisals of the donated building that were not qualified; neither valuation was timely or established the asset’s fair mark ...

Alli v. Commissioner

Tax Court says petitioner failed IRC’s section 170 requirements for charitable contribution deduction because his claim leaned on appraisals of the donated building that were not qualified; neither valuation was timely or established the asset’s fair mark ...

Federal Court Clarifies When IRS Can Subpoena Appraiser’s Work File

9th Circuit confirms that IRS may subpoena appraiser’s work files when the taxpayers’ liability has not yet been “finally determined”—and also no privilege or protections when the report was prepared primarily to comply with tax laws.

United States v. Richey

Ninth Circuit confirms that IRS may subpoena appraiser’s work files when the taxpayers’ liability has not yet been “finally determined;” and also, no privilege or protections when the report was prepared primarily to comply with tax laws.

Business valuation expert can make or break case; How to locate and evaluate qualified business appraisers

Recognition and use of professional business appraisers has risen dramatically in recent years. This is partly due to the educational programs of professional appraisal organizations and partly due to ...

IRS releases recommendations on valuation policies

It has long been known that there are serious deficiencies in the Internal Revenue Service's valuation policies. There is a lack of cohesiveness in valuation reporting requirements and an absence of u ...

"Tax Penalties Related to Valuation Issues,"

Reilly, Robert F., "Tax Penalties Related to Valuation Issues," CPA Expert , Spring/Summer 1998, pp. 9-11. The article is a concise but comprehensive summary of the valuation-related penalties for ...

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