Gulig (Estate of Strangi) v. Commissioner (II)
The court of appeals found no obvious reason for the denial of the IRS's Section 2036 claim and remanded for consideration of the claim and revaluation if necessary.
Emory responds to Dr. Bajaj: miniscule adjustments warranted
In this article, John Emory and his colleagues address Dr. Bajaj's criticism of their pre-IPO discount for lack of marketability studies ( BVU , March 2002, pp. 12-14). The result is no adjustment to ...
Estate of Harper v. Commissioner
Tax Court ruled that 100 percent of the property within the partnership, despite the fact that the partnership was validly formed, was includable in the gross estate under Sec. 2036 (a).
Estate of Godley v. Commissioner (II)
Estate argued that the question of whether decedents fifty percent interest represented a lack of control was a question of law. The Court of Appeals flatly disagreed.
Estate of Mitchell v. Commissioner (III)
The Tax Court, reaching the same final valuation conclusion, again applied a 35% discount on remand.
Estate of Fontana v. Commissioner
The issue was whether two blocks of stock had to be aggregated for valuation purposes.
Latest REIT statistics
2001 NAREIT Statistical Digest , NAREIT, 1875 Eye St., NW, Suite 600, Washington, D.C. 20006-5413, www.nareit.com. This software tool produced by the National Association of Real Estate Inv ...
2002-2010 tax law changes
The New Estate, Gift and Generation Skipping Law, Curtis R. Kimball, Insights , Autumn 2001, Willamette Management Associates, www.willamette.com . This article discusses the gift and es ...
40% 'Aggregate' Discount: Marketability, Control, and Unrealized Capital Gains
The IRS determined that decedent's estate owed amounts for estate tax and gift tax deficiencies.
5th Circuit Acknowledges Substantial Built-In Tax Liability on Timber Property
The issue on appeal was whether the Tax Court erred in the valuation of closely held stock and improperly denied a full discount for capital gains liability.
What's new online at BVLibrary.com
BVLibrary is a website designed with the business valuation professional in mind. It offers instant access to the latest business valuation research ...
Discounts may apply when company holds nonhomogeneous assets or a diverse portfolio
Shannon Pratt's latest book Business Valuation Discounts and Premiums thoroughly discusses the well-known minority and marketability discounts. However, it also covers less familiar discounts, such as ...
Estate of Dailey v. Commissioner (I)
At issue are the valuation of certain retained and gift interests in a Family Limited Partnership (FLP).
Buy-Sell Agreements Fail Lauder II Test and Are Considered Testamentary Devices
This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.
Estate of Jameson v. Commissioner
At issue is whether the Tax Court erred in valuing assets of Johnco, Inc. ("Johnco"), a holding company that is part of the estate.
5th Circuit Reverses Tax Court's Capital Gains Discount 'Model'
The issue on appeal was whether the Tax Court erred in the valuation of closely held stock and improperly denied a full discount for capital gains liability.
Shackleford v. United States
At issue is whether a statutory anti-assignment restriction on lottery payments justifies departure from the Department of Treasury's annuity tables when determining the asset's present value.
Fair Market Value Trumps IRS Valuation Tables
In 1987, Thomas J. Shackleford bought a California Lottery ticket for $1 and won the jackpot.
The Anatomy of Valuing Stock in Close Held Corporations: Pursuing the Phantom of Objectivity into the New Millennium
Stephen J. Leacock Columbia Business Law Review , 2001 Issue This article discusses several valuation approaches followed by the courts, particularly with valuation disputes concerning close ...
Estate of O'Neal v. United States
At issue is the valuation date of the value of a deduction claimed by the estate.
11th Circuit Holds Claims Against Estate Do Not Include Post-Death Events
This is an appeal from the United States District Court for the Northern District of Alabama.
Estate of Schwan v. Commissioner
At issue is the valuation of the decedent's stock in a closely-held corporation for purposes of computing the gross estate and the allowable charitable deduction under Federal tax laws.
Redemption Agreement Did Not Affect Value of Decedent's Estate
The petitioners in this case, decedent's estate and a charitable foundation (the Martin M. Schwan Foundation), challenged the IRS' determination that the estate had a tax deficiency based on a bequest to the foundation and that the foundation was liable as a transferee.
The LLC as a Family Life Insurance Planning Tool
Schimmelbusch, Erik S. Oregon Estate Planning and Administration Section Newsletter , April 2001, Volume XVII, Number 2 This article presents the risks and benefits of using LLCs to hold life i ...
Valuation uncertainty continues – the Ninth Circuit reverses the Tax Court
The recent enactment of the Economic Growth and Tax Relief Reconciliation Act of 2001 1 (Act) poses new challenges and opportunities alike to owners of substantial estates and their profess ...