At issue is the transferral of assets for an interest in partnership (operated by decedent's son) was a "bona fide" sale or not, thus incurring Section 2036 consideration.
T.C. Memo. 2004-116 UNITED STATES TAX COURT ESTATE OF GEORGE C. BLOUNT, DECEASED, FRED B. AFTERGUT, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 540-02. Filed May 12, 2004. D and J each owned 50 percent of the outstanding shares of B corporation. In 1981, D, J, and B entered into a buy-sell agreement restricting transfers of Bs stock both during the shareholders lifetimes and at death. Lifetime transfers required the consent ...
At issue is the validity of discounts applied taking into consideration a business loan agreement.
The only issue in these consolidated cases was whether assets owned by each of five family limited partnerships (FLPs) were includible in the gross estates of Mr. and Mrs. Stone under I.R.C.
At decedent’s death, she owned 3,276 shares of Royal Bancshares Inc. (RBI), or 5.09% of the outstanding RBI shares.
At issue is the inclusion of certain properties in the gross estate which decedent had transferred while alive but from which retained generated income.
DLOM supported by restricted stock studies upheld while neither expert's minority interest discounts are upheld for lack of supporting analysis (therefore higher discount used).
At issue is the classification of a lottery prize issued in annual payments as a private annuity, thereby being valued using annuity tables (by the Tax Court) and thus without discounts.
The U.S. Court of Appeals considered whether deviation from the annuity tables in Sec. 7520 was warranted in the valuation of a lottery prize.
At issue is the inclusion of assets of five various family limited partnerships in the gross estates of Mr. and Ms. Stone under section(s) 2036 and 2044.
The decedent, Helen Deputy, formed a family limited partnership comprised of 99% of a limited partnership interest retained by Deputy and two 0.5% general partnership interests, one held by Deputy and one held by her son.
The original Tax Court ruling in this case was Estate of Strangi v. Commissioner, 115 T.C. No. 35 (U.S. Tax Ct. Nov. 30, 2000).
Issue was the fair market value of a 19.99% interest of stock owned by an FLP, and court discussed negative industry risk premium and unique matrix for determining marketability discount.
Issue on remand is whether the value of property transferred is includable in his gross estate pursuant to section 2036(a).
The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships: the Thompson Turner Family Limited Partnership ("Turner Partnership") and the Thompson Family Limited Partnership ("Thompson Partnership").
The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships.
This case is the 5th Circuit's review of the Tax Court case, Estate of Strangi v. Commissioner, 115 T.C. No. 35 (U.S. Tax Ct. Nov. 30, 2000), abstracted in the January 2001 BVU.
Tax Court ruled that 100% 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).
This case is on a remand from the 9th Circuit Court of Appeals.
At the time of his death, decedent owned a 50% interest in five general partnerships.
The full Tax Court reviewed this federal estate tax matter.
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.
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 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.
The Tax Court, reaching the same final valuation conclusion, again applied a 35% discount on remand.