Net Gift Doctrine Not Applicable If Obligation Too Speculative
Decedent held a controlling interest in National Fruit Products Inc., a privately held corporation.
11th Circuit Affirms Shepherd v. Commissioner
This gift tax case is an appeal from the Tax Court's December 2000 decision, which was abstracted in the December 2000 issue of Shannon Pratt's Business Valuation Update®, at page 5.
Hackl v. Commissioner (I)
The issue was whether the gifts were present interests or future interests under Section 2503(b) of the tax code.
Gifts of Future Interest Do Not Qualify for Sec. 2503(b) Exclusion
The full Tax Court considered whether gifted LLC units subject to a restrictive operating agreement were gifts of a present or future interest in the gifted property for the purposes of the annual gift tax exclusion.
Field Service Advice 200143004
Field Service Advice 200143004. The issues were: (1) Whether donor’s family corporation (FC) lacks economic substance and should be disregarded for gift tax purposes; (2) Whether donor made a gift of ...
Shepherd v. Commissioner (II)
Issues were characterization of ifts as indirect gifts and proper application of stipulated combined minority and marketability discount.
A Gross Result in the Gross Case Calls Into Question Circumstances in Which Tax Affecting Is Valid
Appraisers may soon have to defend their tax affecting in prior S corporation valuations as a result of Gross.
Daubert Issue Rears Its Ugly Head in Gross Case
George Hawkins wrote a guest abstract of this case in the January 2002 issue of Shannon Pratt's Business Valuation Update focusing on the tax affecting issues in the case.
Estate of Armstrong v. United States
The estate argued the "net gift doctrine," contending that the children's obligation to pay additional gift taxes as a condition of the gifts had substantially reduced the value of ...
40% 'Aggregate' Discount: Marketability, Control, and Unrealized Capital Gains
The IRS determined that decedent's estate owed amounts for estate tax and gift tax deficiencies.
Gross v. Commissioner (II)
Issues involved tax affecting of the discounted cash flows of the company and the size of the marketability discount.
0% Reduction for Tax Affecting Affirmed
The 6th Circuit affirmed the Tax Court’s valuation of gifted minority interests in a closely held S corporation.
What's new online at BVLibrary.com
BVLibrary is a website designed with the business valuation professional in mind. It offers instant access to the latest business valuation research ...
Estate of Dailey v. Commissioner (I)
At issue are the valuation of certain retained and gift interests in a Family Limited Partnership (FLP).
Buy-Sell Agreements Fail Lauder II Test and Are Considered Testamentary Devices
This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.
The Anatomy of Valuing Stock in Close Held Corporations: Pursuing the Phantom of Objectivity into the New Millennium
Stephen J. Leacock Columbia Business Law Review , 2001 Issue This article discusses several valuation approaches followed by the courts, particularly with valuation disputes concerning close ...
Estate of True v. Commissioner
1Cases of the following petitioners are consolidated herewith: Jean D. True, docket No. 3408-98 and Estate of H.A. True, Jr., Deceased, H.A. True, III, Personal Representative, docket No. 3409-98. T.C. Memo. 2001-167 UNITED STATES TAX COURT ESTATE OF H.A. TRUE, JR., DECEASED, H.A. TRUE, III, PERSONAL REPRESENTATIVE, AND JEAN D. TRUE, ET AL.1, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 10940-97, 3408-98, Filed July 6, 2001. 3409-98. Buford P. Berry, Emily A. Parker ...
Buy-Sell Agreements Are Testamentary Devices
This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.
Buy-Sell Agreements Do Not Control for Estate Tax Purposes
The Tax Court considered whether buy-sell agreements controlled the value of the business interests the decedent held for estate and gift tax purposes.
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 ...
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 ...