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.
Tax Court Finds 12% Minority Discount and 23% DLOM for Cash-Only FLP
In April 1999, Webster Kelley and his daughter and son-in-law (the Loudens) formed Kelley-Louden Business Properties LLC (KLBP LLC), and Kelley-Louden Ltd., a family limited partnership (KLLP).
Estate of Blount v. Commissioner (II)
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.
Estate of Kelley v. Commissioner
In April 1999, Webster Kelley and his daughter and son-in-law ("the Loudens") formed Kelley-Louden Business Properties, LLC (KLBP LLC), and Kelley-Louden, Ltd., a family limited partnership (KLLP).
Keller v. United States (I)
In this estate tax case, portions of an appraisal report were challenged as inadmissible.
Sec. 2036 Exception Requires Case-By-Case Analysis
The U.S. District Court for the Southern District of Texas denied the government’s motion for summary judgment on the issue of the applicability of sec. 2036 to look through a FLP.
Hypothetical Partition Discount Is Insufficient for Fractionalized, Noncontrolling Interests
In this estate tax case, the issue was whether the IRS' position in applying discounts to fractional, noncontrolling interests in timberland was justified for purposes of determining whether taxpayers were entitled to administrative and litigation costs.
5th Circuit Affirms Tax Court’s Application of § 2036 to FLP Assets
In this last installment of the Strangi case, the 5th Circuit affirmed the Tax Court’s decision on remand that Strangi had retained enjoyment of the assets he had transferred to Strangi Family Limited Partnership (SFLP) and Stranco, Inc. through an implied agreement, and, thus, that the transferred assets were properly included in his estate under IRC Section 2036(a) for estate tax purposes.
Another FLP Bites the 2036 Bullet
In this estate tax case, the issue was whether the value of assets contributed to a family limited partnership (FLP) was includable in the decedent’s gross estate; the Tax Court held it was.
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.
1st Circuit Affirms FLP Case Against Taxpayer
The 1st Circuit affirmed all aspects of a Tax Court determination unfavorable to the estate of Ida Abraham (the Estate).
Transfers of Stock to Business Trusts Not Included in Decedent’s Gross Estate
Schutt, I, Business Trust (Schutt I) and Schutt, II, Business Trust (Schutt II), both Delaware business trusts, were formed in 1998.
Estate of Strangi v. Commissioner (IV)
In this last installment of the Strangi case, the Fifth Circuit affirmed the Tax Court's decision on remand that Strangi had retained enjoyment of the assets he had transferred to Strangi Family Limited Partnership (SFLP) and Stranco, Inc.
Estate of Baird v. Commissioner
In this estate tax case, the issue was whether the IRS's position in applying discounts to fractional, non-controlling interests in timberland was justified.
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.
Estate of Schutt v. Commissioner
Schutt, I, Business Trust (Schutt I) and Schutt, II, Business Trust (Schutt II), both Delaware business trusts, were formed in 1998.
Estate of Abraham v. Commissioner (II)
The First Circuit affirmed all aspects of a Tax Court determination unfavorable to the estate of Ida Abraham (the Estate).
Estate of Korby v. Commissioner
In this estate tax case, the issue was whether the value of assets contributed to a family limited partnership (FLP) was includable in the decedent's gross estate; the Tax Court held it was.
Estate of Bongard v. Commissioner
In this estate tax case, there were two issues: whether pursuant to IRC Sections 2035(a) and 2036(a), (b) the gross estate should have included: (1) shares Wayne Bongard (decedent) transferred to a holding company and (2) the holding company's membership ...
Brief - Petitioner's Response to Brief For Respondent - Estate of Reichardt v. Commissioner
This is the taxpayer's response to the IRS brief in Estate of Reichardt v. Commissioner, a case involving a 36.46% limited partnership interest and IRC § 2036(a).
Brief - Petitioner's Opening Brief - Estate of Reichardt v. Commissioner
This is the opening brief filed by the taxpayer in Estate of Reichardt v. Commissioner, a case involving a 36.46% limited partnership interest and IRC § 2036(a).
Expert takes issue with abstract of Borgatello case
Expert takes issue with abstract of Borgatello case Although this Reader/Editor Exchange letter was directed to Shannon Pratt’s Business Valuation Update version of the Borgatello a ...
Related Parties’ Buy-Sell Agreement Disregarded, but Life Insurance Proceeds Included in Value
The issue in this estate tax case was the value of decedent’s interest in a closely held company on the date of his death.
5th Circuit Holds LLC and Limited Partnership Transfers Were Bona Fide
In this estate tax case, the 5th Circuit vacated and remanded the district court’s granting of summary judgment to the Commissioner on the grounds that the transfer under IRC §2036 was a bona fide sale for full and adequate consideration.
Continued Enjoyment of Property Leads to Disregard of FLPs
The issue in this estate tax case was whether three family limited partnerships (FLPs) should be respected for estate tax purposes.