Gift Tax Case Pivots on Key Assumption Informing Valuations
Taxpayer parents incurred gift tax liability when, based on improper valuations, they agreed to merge their S corp. with their sons’ S corp. and accepted an unduly low interest in the new company while sons received an unduly high interest, Tax Court says ...
Cavallaro v. Commissioner
Taxpayer parents incurred gift tax liability when, based on improper valuations, they agreed to merge their S corp. with their sons’ S corp. and accepted an unduly low interest in the new company while sons received an unduly high interest, Tax Court says ...
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.
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 ...
OBTAINING INFORMATION TO COMPLETE THE FORM 706
This in-depth article focuses on an estate planning attorney's responsibility to educate the personal representative of a decedent's estate of their obligation to file the Form 706, United States Esta ...
Protecting Your Valuation Expert and the Valuation Opinion
n Protecting Your Valuation Expert and the Valuation Opinion, Hood, Paul. Focus On Advanced Estate Planning Workshops . Planning for the Future, LLC. 19267 Slemmer Rd., Ste. 101, Covington, LA 7 ...
Federal and State Taxation of Limited Liability Companies, 1999 Edition
n FEDERAL AND STATE TAXATION OF LIMITED LIABILITY COMPANIES, 1999 Edition Cartano, David Panel Publishers, A Division of Aspen Publishers, Inc. , 1185 Avenue of the Americas, New York, NY 10036 ...
Structuring Buy-Sell Agreements: Analysis with Forms, Zaritsky, Howard M.
Warren, Gorham & Lamont of the RIA Group , 31 St. James Avenue, Boston, Mass. 02116, (800) 950-1216. Available for $205, twice-yearly supplements available for $79 each. Hardbound loose-leaf, 6 ...
Preparing Valuation Reports to Withstand Judicial Challenge
Willis, Robert T. Jr ., "Preparing Valuation Reports to Withstand Judicial Challenge," Estate Planning , December 1998, pp. 455-462. This article analyzes what the courts have said is deficient ...
Packwood predicts that Clinton's proposal to eliminate FLP discounts from NAV will pass
Shannon Pratt: Senator, I know from conversations in earlier years that you have a great depth of interest and knowledge regarding the U.S. tax system. Do you still keep up with current tax issues?
Valuation Practice in Estate Planning
Elliott, W. Curtis Jr., William R. Culp, Jr., and Richard E. Marsh, Jr. Valuation Practice in Estate Planning & Litigation. West Group, 620 Opperman Dr., Eagan, MN 55123; Phone (800) 221-9428 ...
Fiore advocates cooperation
In the past few issues of Business Valuation Update, there has been much coverage of FLP valuation, due to a combination of developing appraisal methodology and IRS stepped-up challenges of ...