9th Circuit Vacates and Remands Tax Court's Valuation in Mitchell
In this ongoing estate tax proceeding, the Estate of Paul Mitchell (Estate) appealed the U.S. Tax Court's decision allowing the Commissioner of the IRS to assess an additional $2,404,571 in federal estate taxes.
Technical Advice Memorandum 9725002
PRIVATE RULING 9725002 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code."
Federal Tax Valuation
FEDERAL TAX VALUATION, Bogdanski, John A. Warren, Gorham & Lamont, 117 East Stevens Avenue, Valhalla, New York 10595, (800) 431-9025. Available for $205, updated twice annually for approxim ...
Recent Court Decisions Point Up Importance of Underlying State Law in Family Partnerships
RECENT COURT DECISIONS POINT UP IMPORTANCE OF UNDERLYING STATE LAW IN FAMILY PARTNERSHIPS , Abraham, Mel H. Valuation Strategies , November/December 2000 This article examines two recent court ca ...
IRC § 7520
LEXSTAT IRC § 7520 INTERNAL REVENUE CODE Copyright 2000, LEXIS Law Publishing, a division of Reed Elsevier Inc. All rights reserved. *** CURRENT THROUGH P.L. 107-7, APPROVED 4/12/01 ...
IRC § 2703
LEXSTAT IRC sec. 2703 INTERNAL REVENUE CODE Copyright 2000, LEXIS Law Publishing, a division of Reed Elsevier Inc. All rights reserved. *** CURRENT THROUGH P.L. 107-7, APPROVED 4/12 ...
IRC § 2704
LEXSTAT IRC § 2704 INTERNAL REVENUE CODE Copyright 2000, LEXIS Law Publishing, a division of Reed Elsevier Inc. All rights reserved. *** CURRENT THROUGH P.L. 107-7, APPROVED 4/12/01 ...
Oppressed Shareholders' Rights Can Affect Estate and Gift Tax Valuation
Greene, Martin, and Douglas Schnapp The CPA Journal , February 2001 This article initially distinguishes the rights of different classes of minority shareholders. Oppressed shareholders' inter ...
Estate of Simplot v. Commissioner (II)
Ninth Circuit reversed and ordered entry of judgment in favor of the estate on remand because the Tax Court erroneously attributed a premium to minority voting stock.
Estate of Hoffman v. Commissioner
At issue is the fair market value of property interests held by decedent at the time of her death.
Appraisers Apply Myriad of Valuation Techniques to Various Estate Holdings
Marcia Hoffman's (decedent) estate held a 27.5% interest in Clubside Partnership, which was family owned.
Estate of Mitchell v. Commissioner (II)
Estate claimed Tax Court erred by failing to provide a detailed explanation of the methodology used to calculate FMV, miscalculating the value, and failing to shift the burden of proof.
Avoiding field audits of estate tax returns; A survey of IRS estate tax attorneys
As a result of IRS staffing reductions, the historic estimate that approximately 38% of 706's receive field audit is high. One IRS attorney estimated the recent field audit percentage to be closer to ...
9th Circuit Reverses Kaufman; Actual Sales Best Evidence
This case is the 9th Circuit Court of Appeals' decision on appeal of Estate of Kaufman v. Commissioner, T.C. Memo 1999-119 (1999), which was abstracted in the May 1999 Business Valuation Update.
The IRS' 'More Reliable' Valuation Accepted Over Estate Valuation
This case involves a hearing on remand from the 9th Circuit to provide sufficient analysis of the consideration value of common and preferred stock in two closely held companies transferred and received by Cyril Magnin, the life estate holder.
More Good News on Estate and Gift Valuation
In this interview with Owen G. Fiore , an estate planning attorney with the Fiore Law Group, CCH, asks Fiore about the new IRS adequate disclosure regulations and the recent case of Kerr v. Commissi ...
Adequate Disclosure of Gifts
FEDERAL REGISTER Vol. 64, No. 232 Rules and Regulations DEPARTMENT OF THE TREASURY Internal Revenue Service (IRS) 26 CFR Parts 20, 25, 301 and 602 [TD 8845] RIN 1545-AW20 Adequ ...
Revenue Ruling 59-60
Rev. Rul. 59-60 SECTION 2031. - DEFINITION OF GROSS ESTATE 26 CFR 20.2031-2: Valuation of stocks and bonds. (Also Section 2512.) (Also Part II, Sections 811 (k), 1005, Regulations 105, Section 81.
Technical Advice Memorandum 9736004
PRIVATE RULING 9736004 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) of the ...
Technical Advice Memorandum 9842003
PRIVATE RULING 9842003 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) o ...
Estate of Forbes v. Commissioner
Issue is fair market value of 42% and 42.9% undivided interests in two real estate parcels held by the QTIP, and what fractional discount should apply.
Morrissey v. Commissioner
FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT JAMES J. MORRISSEY; ALAN S. BERCUTT, C.P.A.; DIANE FANTL, Co-executors of the Estate of Alice Friedlander Kaufman, No. 99-71013 Deceased, Tax Ct. No. Petitioners-Appellants, 17050-97 v. OPINION COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted February 14, 2001--San Francisco, California Filed March 15, 2001 Before: Procter Hug, Jr., John T. Noonan, and William ...
Transactions Occurring Shortly After the Valuation Date Are Probative
The U.S. Court of Appeals for the 9th Circuit considered the Tax Court’s valuation of an Oklahoma company holding a uniform manufacturer in Estate of Kaufman v. CIR, T.C. Memo. 1999-119.
Financial and Estate Planning Techniques: Q&A, CCH
Financial and Estate Planning, Issue 505, December 15, 2000 This insightful article, in question and answer format, draws on the knowledge of members of the CCH Financial and Estate Planning A ...
Same Day Case Makes Interesting Addendum to Knight
In 1993 and 1994, decedent Albert Strangi was suffering severe medical problems.