Weinberg v. Commissioner
At issue is the fair market value of a limited partnership interest over which the decedent had a general power of appointment on the date of her death.
Estate of Dunn v. Commissioner (I)
At issue is the fair market value of 492, 610 shares of Dunn Equipment.
Estate of Brocato v. Commissioner
At issue is whether respondent is equitably estopped from assessing additional estate tax, and if not, the proper amount of blockage and fractional interest discounts to be applied to petitioner’s nine real properties must be determined.
11% Blockage Discount Applied in Apartment Valuations
The taxpayer in this estate tax matter 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.
Fractional Interest and Blockage Discount Considered
The Tax Court considered the size of discounts for blockage and fractional interests on nine rental properties.
Petitioners' expert accepted despite their claim of lower value
The Experts: Clifford Braly III (for taxpayers on returns) Deloitte & Touche Management Planning, Inc. (for petitioners at trial) William H. Frazier, ASA (for petitioners ...
Estate of DiSanto v. Commissioner
At issue is the fair market value of a block of 186,177 shares of MD&F stock owned by the decendent.
Petitioners' Expert Accepted Despite Their Claim of Lower Value: Marital Deduction Based on Stock Actually Inherited After Disclaimer
The issues in the estate tax matter were: the fair market value of Frank DiSanto's (Frank) 186,177 shares (53.5%) of stock in Morganton Dyeing & Finishing Corp. (MD&F) on the date of death; the fair market value of the MD&F stock Grace DiSanto (Grace) was entitled to inherit from Frank's estate (a minority interest) on her date of death; whether Grace had expectancy interest only in the stock she was entitled to inherit; and whether Frank's estate was entitled to a marital deduction based on the value of the stock he willed to Grace or based on the value of the stock she was entitled to receive after executing a disclaimer of part of her interest in the stock.
A Post-Valuation Date Redemption and a Marital Deduction
The Tax Court determined that the fair market value of stock in a fabric dying corporation.
Tax Court Holds Sales Transactions Not Indicative of FMV
This issue in this estate tax matter was the fair market value on Sept. 7, 1993, of decedent's 366,385 shares of common stock of Hastings Books, Music & Video Inc.
Estate of Marmaduke v. Commissioner of Internal Revenue
At issue is the fair market value, as of the date of decedent's death, of 366,385 shares of common stock of a closely held corporation.
Small-Block Sales Not Indicative of FMV; 30% Marketability Discount Applied
The issue in this estate tax matter was the fair market value on Sept. 7, 1993, of decedent's 366,385 shares of common stock of Hastings Books, Music & Video Inc., a closely held corporation.
Illiquidity Increases With Block Size
The Tax Court determined the fair market value, including a discount for lack of marketability, of a large block of stock in a retail books, music, and video chain operating in the South and Southwest.
Estate of Rodgers v. Commissioner of Internal Revenue
At issue is is the fair market value of the interest that Lynn M. Rodgers (decedent) owned on the date of his death in Marrero Land and Improvement Association, Limited.
Absorption Discount Applied to Value Assets
The issue in this estate tax matter is the valuation of decedent's 166 2/3 shares of stock representing one-third of the total of Marrero Land, a real estate operating company that engages in "the business of acquiring, developing, managing, improving, maintaining, leasing, and selling real estate."
Appellate Court Decides Redemption Price Controls Based on Treasury Regulations
The only issue in this case is whether the price in a stock redemption agreement entered into between the decedent and the corporation is determinative for estate tax purposes.
Landmark court cases give educational insights
In ASA and AICPA classes that I taught in the last month, I cited certain landmark court cases, and several students who were already newsletter and BVU Online subscribers suggested that I share the ...
Estate of Gloeckner v. Commissioner
Issue in this case is whether the price in a stock redemption agreement entered into between the decedent and the corporation is determinative for estate tax purposes.
Court Disallows Built-In Capital Gains Discount
At issue is whether the estate of Welch is entitled to discount the value of stock for built-in capital gains taxes, causing a deficiency of $59,987 in federal estate taxes.
Aggregation of estate interests
Assume Dad owns 100% of the general partnership interest in a limited partnership, and substantially all the limited partnership interests. The general partner has the unilateral right to s ...
Estate of Welch v. Commissioner (I)
At issue is whether the estate of Welch is entitled to discount the value of stock for built-in capital gains taxes.
Institute of Business Appraisers 20th anniversary conference open with IRS attorney; closes with estate planning attorney
n LITIGATING ISSUES IN THE FAMILY LIMITED PARTNERSHIP ARENA Melanie Urban, Esq. Internal Revenue Service Houston, TX Ms. Urban opened with a declaration that there are two things that the IR ...
Court Values Stock at Subsequent Sale Price
Although there are other assets at issue in this case, our review is limited to the value of 1,533.482 shares of a certain class of Sterling Holding Co. preferred stock as of the alternate estate valuation date, Sept. 18, 1992.
Estate of Trompeter v. Commissioner (I)
Issue was the fair market value of 1,533.482 shares of a certain class of Sterling Holding Co. preferred stock.
Court Allows Both Minority and Marketability Discounts for 50% Stock Interest
The issue is the value of a 50% stock interest in a small consumer loan company with a book value of $2,168,839.