Dallas v. Commissioner
In a post-Gross decision, the Tax Court considers tax-affecting S Corp earnings and also discounts for lack of marketability and control.
Yet Again, Delaware Looks to DCF in Appraisal Action
PNC Financial Services Group Inc. (PNC), the parent of PFPC Holding Corp. (Holding), had planned to take Holding’s subsidiary, PFPC Worldwide Inc. (PFPC), public via an initial public offering (IPO), but the opportunity did not arise.
Valuation Upheld Against Party That Fails to Use Independent Valuation Sources
Verizon Inc. had offered to buy MCHC’s majority holder, Palmer Wireless Holdings (Palmer), if Verizon’s initial public offering was successful and if Palmer could acquire 100% of the stock in all of the companies it held.
Control Premium Not Needed for DCF Analysis Using Gordon Growth Model
One of the issues was whether the board’s financial advisor, Credit Suisse First Boston (First Boston), correctly excluded a control premium in its assessment of the company’s value and, thus, whether the board failed to reasonably consider the value of all relevant alternatives.
Marketability discount may be applied where there is no impending sale but is within court’s discretion
The valuation issues in this marital dissolution were whether a discount for lack of marketability should have been applied to husband’s minority interests in two medical-practice businesses, and whether a buy-sell provision in a third business was determinative of that business's fair market value.
Built-In Capital Gains Liability of Small Minority Interest Should Be Discounted to Reflect Time Value of Money
The issues in this estate tax case were whether built-in capital gains tax liability should be discounted (indexed) to account for time value and the appropriate discounts for lack of marketability and control.
Andaloro v. PFPC Worldwide, Inc.
PNC Financial Services Group, Inc. (PNC), the parent of PFPC Holding Corp. (Holding), had planned to take Holding's subsidiary, PFPC Worldwide, Inc. (PFPC), public via an initial public offering (IPO), but the opportunity did not arise.
Montgomery Cellular Holding Co., Inc. v. Dobler
Verizon Inc. had offered to buy MCHC’s majority holder, Palmer Wireless Holdings (Palmer), if Verizon’s initial public offering was successful and if Palmer could acquire 100% of the stock in all of the companies it held.
In re Toys “R” Us, Inc., Shareholder Litigation
One of the issues was whether the board’s financial advisor, Credit Suisse First Boston (First Boston), correctly excluded a control premium in its assessment of the company’s value, and, thus, whether the board failed to reasonably consider the value of ...
Estate of Jelke v. Commissioner (I)
The issues in this estate tax case were whether built-in capital gains tax liability should be discounted (indexed) to account for time value, and the appropriate discounts for lack of marketability and control.
Fausch v. Fausch
The valuation issues in this marital dissolution were whether a discount for lack of marketability should have been applied to husband's minority interests in two medical-practice businesses, and whether a buy-sell provision in a third business was determ ...
Matthews critiques Mercer's Simplot case review
In his review of Estate of Richard R. Simplot v. Commissioner , 112 T.C. No. 13 (1999), Chris Mercer missed the principal point of the decision. The key issue was whether the premium for v ...
Expert dubbed "unpersuasive" rebuts Judge Laro's rejection
I have reviewed the write up of Estate of Kaufman in the May issue of your newsletter, and I am very concerned that it unfairly portrays me as having not done a credible valuation because it takes Judge Laro's criticisms of my report at face value.
Use of fair market value reasonable even where recipient will obtain control
In this probate case, the court of appeals upheld the district court’s decision to use fair market value rather than ...
Husband’s version of the facts not supported by the record
Husband and wife were married in 1979, and wife filed for divorce in 2000.
Tax Court displeased with all experts’ DLOC and DLOM analyses
The primary issues in this gift tax case were the appropriate discounts for lack of control and lack of marketability to apply to gifted and sold interests of a family limited partnership.
Court Uses Raw Data From Bajaj Study to Determine DLOM
The only issue in this case was the fair market value of gifted family limited partnership (FLP) interests.
Tax Court Determines That Value Was 'Somewhere in the Middle' of Expert Opinions
The taxpayers' expert, Gregory Heebink, used the discounted cash flow (DCF) method and the guideline public company method.
Peracchio v. Commissioner
Issues were appropriate discount for lack of control and discount for lack of marketability to apply in valuing gifts of family limited partnership interests.
Lappo v. Commissioner
The issue for decision is the fair market value of interests in a family limited partnership that petitioner transferred in 1996.
In re Estate of King
Issue is whether discounts for marketability and lack of control should be applied to determine value of minority interest in a closely held corporation.
Hess v. Commissioner
Taxpayers gave 10 shares of HII common stock (a 10% stockholder interest) to an irrevocable trust established for their daughter. Issue was the fair market value of the stock for gift tax p ...
Arn v. Arn
Issue is the valuation of husband's interest in wine company where he originally purchased 20% interest and later purchased remaining 80% but sale was still in escrow.
Valuation 'Experts' Excluded as Unreliable Based on Numerous Errors in Methodology and Inability to Explain Conclusions
In this bankruptcy adversary proceeding, the trustees as plaintiffs sought to prove that the defendants—Bairnco Corp., Keene Corp., and the individual managers of the companies—had engaged in a series of fraudulent conveyances among subsidiaries to protect assets from the reach of asbestos claimants.
Lippe v. Bairnco Corp. (I)
In this bankruptcy adversary proceeding, the trustees as plaintiffs sought to prove that the defendants—Bairnco Corp., Keene Corp., and the individual managers of the companies—had engaged in a series of fraudulent conveyances among subsidiaries to protect assets from the reach of asbestos claimants.