Assets transferred to FLP part of estate
Prior to his death, decedent transferred his life interest in his residence, rental properties and other real properties, and investment accounts to the Reichardt Family Trust and Reichardt ...
Assignee's Interest in Partnership May Require Discounting
The issue in this estate tax matter is whether discounts for lack of marketability, minority status, and poor portfolio diversity should be applied in valuing the decedent's 25% interest in a Texas general partnership, which decedent held as an assignee.
Estate of Strangi v. Commissioner (I)
At issue is the fair market value of decedent's interest in the Strangi Family Limited Partnership at the date of death.
Tax Court Determines Capital Gains Discount for Real Estate Holding Company
This issue in this estate tax matter is the fair market value of decedent's 82.76% interest in Valley Improvement Co. Inc. (VIC), a real estate holding company, as of Jan. 12, 1994.
Tax Court Rejects IRS Bid to Overrule Kerr v. Commissioner
The issue in this estate tax matter is whether the provisions of the Limited Partnership Agreement for Harper Financial Co. LP, entered into by the decedent and his two children, were "applicable restrictions" for purposes of IRC § 2704.
Option With No Bona Fide Business Purpose Not Relevant to FMV
This case deals with the valuation for estate tax purposes of four Housing and Urban Development (HUD) housing partnerships and one real estate management partnership.
Borgatello v. Commissioner
T.C. Memo. 200-264 UNITED STATES TAX COURT ESTATE OF CHARLES A. BORGATELLO, DECEASED, C. NORMAN BORGATELLO AND JOSEPHINE E. DONNELLY, CO-EXECUTORS, AND C. NORMAN BORGATELLO, SUCCESSOR TRUSTEE TO THE CHARLES A. BORGATELLO LIVING TRUST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24756-97. Filed August 18, 2000. John W. Ambrecht and Gregory Arnold, for petitioners. Donna F. Herbert, for respondent. MEMORANDUM OPINION WELLS, Chief Judge: Respondent determined a deficiency of $3,424,504 in the ...
Tax Court Allows Capital Gains Discount for Real Estate Holding Company
The issue in this estate tax matter is the fair market value of decedent's 82.76% interest in Valley Improvement Co. Inc. (VIC), a real estate holding company, as of Jan. 12, 1994.
Built-In Capital Gains Considered in Build Up of the Marketability Discount
The Tax Court valued a real estate holding company using the net asset value method.
Estate of Godley v. Commissioner (I)
At issue in the equitable distribution litigation was the value of Fred Jr.'s 50-percent general partnership interest in the partnerships.
6th Circuit Allows Capital Gains Discount
The issue in this estate tax appeal is whether the petitioners were entitled to apply a discount for a built-in capital gains tax liability on real estate in valuing the stock of the corporation owning the real estate.
Adams v. U.S. (II)
At issue is whether discounts for lack of control, lack of marketability, and poor portfolio diversity are applicable when appraising the value of an assignee's fractional interest in a Texas general partnership for estate tax purposes.
Harper v. Commissioner
At issue is whether, pursuant to section 2704(b), restrictions on the right to liquidate certain limited partnership interests in Harper Financial Co., L.P., should be disregarded.
Tax Court Rejects IRS Bid to Overrule Kerr
The issue in this estate tax matter is whether the provisions of the Limited Partnership Agreement for Harper Financial Co. LP the decedent and his two children entered into were "applicable restrictions" for purposes of IRC § 2704.
IRS releases recommendations on valuation policies
It has long been known that there are serious deficiencies in the Internal Revenue Service's valuation policies. There is a lack of cohesiveness in valuation reporting requirements and an absence of u ...
Blockage Discount Appropriate for Apartment House
The taxpayer was granted a 20% fractional interest discount and an 11% blockage discount with apartment house properties, based on comparable sales and an analysis of market conditions and the economy.
Court Accepts Taxpayer's Expert Value Despite Taxpayer Protests
The issues in this estate tax matter were as follows: the fair market value of Frank DiSanto's (Frank) 186,177 shares (53.5%) of stock in Morganton Dyeing & Finishing Corp. (MD&F) on his date of death; and the fair market value of the MD&F stock Grace DiSanto (Grace) was entitled to inherit from Frank's estate (a minority interest) on his date of death.
Equipment Company Valuation Turns on Asset- and Earnings-Based Values
The fair market value of 492,610 shares of stock in Dunn Equipment Inc. is in dispute in this case.
Estate of Reichardt v. Commissioner
114 T.C. No. 9 UNITED STATES TAX COURT ESTATE OF CHARLES E. REICHARDT, DECEASED, WILLIAM D. REICHARDT, INDEPENDENT EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1224-98. Filed March 1, 2000. Decedent (D) had two children, C and W. On June 17, 1993, D formed a revocable family trust (the trust) and a family limited partnership (the partnership). The trust was the general partner of the partnership. D, C, and W were ...
Value of Assets Transferred to a Limited Partnership Is Included in Decedent’s Gross Estate
The Tax Court determined that the estate must include the value of partial interests in real property in its gross estate under IRC sec. 2036. The decedent owned interests and life interest in real property. He had the power to consume the property in w ...
Section 1033 Election Does Not Prohibit Built-In Capital Gains Tax Deduction
The U.S. Court of Appeals for the Sixth Circuit reversed the Tax Court's decision denying the estate a deduction for built-in capital gains taxes embedded in four parcels for real property held by two closely held corporations. The parcels were under the ...
Estate of Welch v. Commissioner (II)
At issue is whether the estate had the right to discount the value of corporate stock to reflect a built-in capital gains tax liability on corporate real estate.
6th Circuit Estate Tax Appeal Allows Capital Gains Discount
The issue in this estate tax appeal is whether the petitioners were entitled to apply a discount for a built-in capital gains tax liability on real estate in valuing the stock of the corporation owning the real estate.
Assets Controlled by Decedent After Transfer to FLP Part of Estate
Prior to his death, decedent transferred his life interest in his residence, rental properties and other real properties, and investment accounts to the Reichardt Family Trust and to Reichardt Partners Ltd., a family limited partnership of which the trust was the only general partner.
Tax Court Rejects QMDM and Use of Single Comparable
In this estate tax matter, the Tax Court addressed basic valuation issues dealing with minority interest and illiquidity discounts in the context of a limited partnership interest.