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Kimbell v. US

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.

Estate of Blount v. Commissioner (I)

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 B’s stock both during the shareholders’ lifetimes and at death. Lifetime transfers required the consent ...

Estate of Hillgren v. Commissioner

At issue is the validity of discounts applied taking into consideration a business loan agreement.

Estate wins 2036 (a) challenge; FLPs did more than "recycle value"`

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.

DLOM Major Issue; Tax Court 'Splits the Baby'

At decedent’s death, she owned 3,276 shares of Royal Bancshares Inc. (RBI), or 5.09% of the outstanding RBI shares.

Estate of Abraham v. Commissioner (I)

At issue is the inclusion of certain properties in the gross estate which decedent had transferred while alive but from which retained generated income.

Estate of Green v. Commissioner

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).

Estate of Cook v. Commissioner

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.

5th Circuit Considered the Valuation of Lottery Payments

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.

Estate of Stone v. Commissioner

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.

Tax Court Accepts Negative Industry Risk Premium and Unique Combined Discount Matrix

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.

Tax Court Rules on Remand That IRC Section 2036 Applies

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).

Estate of Deputy v. Commissioner

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.

Estate of Strangi v. Commissioner (III)

Issue on remand is whether the value of property transferred is includable in his gross estate pursuant to section 2036(a).

Gross Estate Includes Date-of-Death Value of Assets Transferred to Family Limited Partnership

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").

Estate of Thompson v. Commissioner

The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships.

5th Circuit Remands Strangi to Consider § 2036 Claim

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.

Assets of Valid Partnership Included in Gross Estate

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).

29% Lack of Control, 6% Lack of Marketability Discount for a 49% Interest

This case is on a remand from the 9th Circuit Court of Appeals.

4th Circuit Upholds No Minority Discount for 50% Interest in HUD Partnerships

At the time of his death, decedent owned a 50% interest in five general partnerships.

Stock Held Pursuant to GPA Aggregated With Stock Held Outright for Valuation Purposes

The full Tax Court reviewed this federal estate tax matter.

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.

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.

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