Court Applies Discounts for Key Person and Pending Litigation in Estate Valuation
The issue is the fair market value of 1,226 shares of Paul Mitchell Systems common stock, constituting 49.04% of the shares outstanding, as of April 26, 1989, the date of Paul Mitchell's death.
Estate of Letts v. Commissioner of Internal Revenue
At issue is whether or not the decedent's estate includes the value of property that decedent's husband left to her.
Court Utilizes DCF Valuation Method, Decries Failure to Consider Willing Seller
At date of death, decedent owned a 1% general partnership interest and a 23.9650903% limited partnership interest in LKB Associates, a limited partnership organized under the laws of the District of Columbia.
Fleming v. Commissioner
At issue is the fair market value of the stock interest in a small loan company that was owned by Thomas A. Fleming (decedent) at the date of his death.
Estate of Mitchell v. Commissioner (I)
The issue is the fair market value of 1,226 shares of Paul Mitchell Systems common stock, constituting 49.04% of the shares outstanding.
Super ESOP champions launch two front campaign to promote ESOPs
The ESOP Association. "Super ESOP Champions Launch Two Front Campaign to Promote ESOPs." ESOP Report . July, 1997. p. 1. The article addresses legislation pending in both houses of Congress. Sena ...
Deposits of FLP Income to Personal Bank Account Cause Disallowance of Gifts
The decedent, Dorothy Schauerhamer, established three partnerships to which she gifted assets, primarily commercial real estate.
Lehmann v. Commissioner
At issue is whether petitioner correctly valued the partnership interests in LKB Associates for purposes of decedent's gross estate.
Wheeler v. United States
Issue is whether sale of remainder interest for less than value of full fee simple interest in ranch constitutes adequate consideration for the purposes of section 2036(a).
Schauerhamer v. Commissioner
At issue is whether the value of certain assets transferred to family partnerships is includable in the decedent's gross estate.
Family Limited Partnership Disregarded Where Decedent Used Partnership Funds for Personal Expenses
The Tax Court concluded that three family limited partnerships should be disregarded and the value of their assets included in the value of the decedent's gross estate under IRC sec. 2036.
Estate of D'Ambrosio v. Commissioner
Issue is whether entire fee simple value of stock was part of gross estate even though the decedent had sold her remainder interest in the stock for its fair market value.
Remainder Interest Included in Gross Estate at FMV
The 3rd Circuit reversed the Tax Court and concluded that the decedent received adequate consideration under IRC sec. 2036 when she exchanged her stock for an annuity.
IRS estate tax audit approves trapped-in gains tax deduction
In your February, 1996 column entitled "Trapped-in Capital Gains Affects Real World Value," you mention that the IRS has not yet shared the view that unrealized capital gains should be refle ...
Stock gifted to husband awarded to wife in divorce
The brief of appellant (husband) states the issue, "Did the trial court abuse its discretion in distributing the marital estate by awarding 93.72% ($1,380,630) of the marital estate to the wife and 6.
France v. France
At issue is the valuation of wife's the valuation stock in a ranching corporation.
Estate of Ford v. Commissioner
At issue is the valuation of five closely held corporations of the in which Ray A. Ford held varying degrees of ownership on the date of his death.
Estate of Frank v. Commissioner
Issues are whether 91 shares of common stock are includable in decedent's gross estate pursuant to sections 2038(a)(1) and 2035(d)(2), and valuation of the stock.
Estate of Luton v. Commissioner
Issues are value of 78-percent interest in Rancho San Juan, Inc., one-third interest in Dune Lakes, Ltd., and 41.9-percent interest in the Miramonte Liquidating Trust, and penalties for und ...
Estate of Lauder v. Commissioner
Dispute regarding the fair market value of the stock in question centers on the effect of a shareholder agreement executed prior to Lauder's death.
Estate of Lauder v. Commissioner
The marketability discount issue involved the valuation of estate shares in a closely held family corporation, given a restrictive transfer of shares provision in the stockholder agreement.
Estate of Simpson v. Commissioner
At issue is the valuation of stock for gift tax purposes.
Hutchens Non-Marital Trust v. Commissioner
At issue is the valuation of the stock of a family-owned corporation for estate gift tax purposes.
Hutchens v. Commissioner
The marketability discount issue in this case arose in connection with the question of whether the common stock decedent and his wife surrendered in a recapitalization of their family-owned corporation was worth more than the preferred stock they received, thus resulting in taxable gifts.
Estate of Jung v. Commissioner
Issues are the fair market value of decedent's 168,600 shares of Jung Corp. stock and whether petitioner is liable for an addition to tax under section 6660.