Eleventh Circuit Affirms Tax Court’s Valuation of Trust’s Interest in LLC
Affirming FMV conclusion, appeals court says Tax Court did not err in focusing less on details of methodology parties’ appraisers used than on larger issue of whether hypothetical seller would be able to force distribution of majority of LLC’s assets.
Estate of Koons v. Commissioner (Koons II)
Affirming FMV conclusion, appeals court says Tax Court did not err in focusing less on details of methodology parties’ appraisers used than on larger issue of whether hypothetical seller would be able to force distribution of majority of LLC’s assets.
Michael Jackson estate valuation case features tainted image and tax affecting
BV experts take the stand in a high-stakes Tax Court case that pits the IRS against the estate of Michael Jackson.
Tax Court Corrects Prior Valuation of LP Interest to Startling Result
On remand Tax Court recalculates decedent’s minority LP interest in family partnership by relying entirely on DCF value and giving no weight to value of company’s timberland assets; newly calculated value is half the original value.
Tax Court Corrects Prior Valuation of LP Interest to Startling Result
On remand Tax Court recalculates decedent’s minority LP interest in family partnership by relying entirely on DCF value and giving no weight to value of company’s timberland assets; newly calculated value is half the original value.
Estate of Giustina v. Commissioner (Giustina III)
On remand Tax Court recalculates decedent’s minority LP interest in family partnership by relying entirely on DCF value and giving no weight to value of company’s timberland assets; newly calculated value is half the original value.
9th Circuit Calls Tax Court Out Over ‘Imaginary Scenarios’
Ninth Circuit orders Tax Court to recalculate value of decedent’s minority interest in longtime family partnership owning timber assets because Tax Court accorded weight to NAV value based on “imaginary scenarios” that saw some possibility of liquidation.
Estate of Giustina v. Commissioner (II)
Ninth Circuit orders Tax Court to recalculate value of decedent’s minority interest in longtime family partnership owning timber assets because Tax Court accorded weight to NAV value based on “imaginary scenarios” that saw some possibility of liquidation.
Estate Valuation Can’t Ignore Historical Data, Tax Court Says
Tax court disapproves of estate’s “conflicting expert reports” as to value of decedent’s 100% interest in a C corp. but ultimately adopts estate’s DCF valuation, finding its treatment of personal goodwill is more credible than the IRS’s approach.
Estate of Adell v. Commissioner
Tax court disapproves of estate’s “conflicting expert reports” as to value of decedent’s 100% interest in a C corp. but ultimately adopts estate’s DCF valuation, finding its treatment of personal goodwill is more credible than the IRS’s approach.
Tax Ct. How-to of Valuing Holding Company, Avoiding Accuracy Penalty
Tax Court favors net-asset-value over capitalized-dividend approach for FMV determination of interest in holding company with marketable securities because NAV starts out on “firm ground” with stock prices one can look up whereas income approach relies en ...
Estate of Richmond
Tax Court favors net-asset-value over capitalized-dividend approach for FMV determination of interest in holding company with marketable securities because NAV starts out on “firm ground” with stock prices one can look up whereas income approach relies en ...
Tax Court Foils ‘End Run’ Around Expert Rules
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 ...
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 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 ...
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.