Court Rejects Expert’s Regression Equation to Determine DLOM
In determining the fair market value of a revocable trust’s interest in an LLC, the Tax Court adopts the IRS expert’s marketability discount and valuation; he rightly assumed it was reasonably foreseeable at the time of the decedent’s death that the trust ...
Estate of Tanenblatt v. Commissioner
Tax Court rejects taxpayer’s attempt to place in evidence a new appraisal regarding the decedent’s interest in an LLC whose principal asset was real estate by way of stipulation, finding he failed to qualify the appraiser as an expert and did not present ...
Estate of Koons v. Commissioner
In determining the fair market value of a revocable trust’s interest in an LLC, the Tax Court adopts the IRS expert’s marketability discount and valuation; he rightly assumed it was reasonably foreseeable at the time of the decedent’s death that the trust ...
Estate of Kite v. Commissioner
At issue in this taxpayer action was whether the transfer of family partnership interests held by the decedent's lifetime revocable trust to her children in exchange for private annuity agreements was a disguised gift subject to gift tax.
IRS and Taxpayer Agree to 35% DLOM—If FLP Transfers Pass ‘Indirect Gift’ Tests
Tax Court accepts stipulated 35% DLOM after finding that FLP funding and transfer is not an indirect gift.
Bianca Gross v. Commissioner
Tax Court accepts stipulated 35% DLOM after finding that FLP funding and transfer is not an indirect gift.
Business Valuation Cases in Brief
Business Valuation Cases in Brief by John J. Stockdale, Jr., JD Estate Valuations In the Estate of Farnam v. CIR, 130 T.C. No. 2 (February 4, 2008), the U.S. Tax Court concluded that loans made to a family business may not be aggregated with equity interests in that business in order to satisfy the 50% ‘‘interest’’ requirement needed to qualify for the family-owned business tax exemption. The court con- cluded that interest as used in ...
Estate of Cyril Magnin v. Commissioner (II)
*This Memorandum Opinion supplements our Memorandum Opinion in Estate of Magnin v. Commissioner, T.C. Memo. 1996-25, revd. and remanded 184 F.3d 1074 (9th Cir. 1999). T.C. Memo. 2001-31 UNITED STATES TAX COURT ESTATE OF CYRIL I. MAGNIN, DECEASED, DONALD ISAAC MAGNIN, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 24883-92. Filed February 12, 2001. Stuart S. Lipton, Frederick J. Adam, Jerome B. Falk, Jr., Douglas A. Winthrop, and Denise M. Riley, for ...
Business Valuation Cases in Brief
A review of cases that present issues of interest within the business valuation community.
Valid Nontax Purpose for Transfer to Holding Company Does Not Save Subsequent Transfer to FLP
This case does a good job of reviewing most of the significant decisions in this area and can serve as a minireference guide to the latest in FLP law.
11th Circuit Disregards Changeable Buy-Sell Agreement, but Insurance Proceeds Used for Buyout Not Included in Value
As reported in the August 2004 issue of Business Valuation Update, the issue in this estate tax case was the value of George Blount’s (decedent’s) interest in a closely held company on the date of his death.