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Same Day Case Makes Interesting Addendum to Knight

In 1993 and 1994, decedent Albert Strangi was suffering severe medical problems.

All Tax Court Judges Have Something to Say in FLP Gift Case

The taxpayer owned 50% of a newly formed family partnership, and his two sons each owned 25%.

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 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.

Shepherd v. Commissioner (I)

At issue is the fair market value of petitioner's transferred real estate interests.

Revenue Ruling 98-21

ISSUE When is the transfer of a nonstatutory stock option (i.e., a compensatory stock option that is not subject to the provisions of § 421 of the Internal Revenue Code ) by the optionee to a family ...

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.

DISCLOSURE SETS TIME LIMIT ON IRS GIFT REVALUATION

n DISCLOSURE SETS TIME LIMIT ON IRS GIFT REVALUATION , Oliver, Joseph R., and Granstaff, Charles A. Tax Strategies , Volume 62, Number 1, January 1999. This article focuses on estate and gif ...

IRS adequate disclosure final regulations respond to extensive comments

On Dec. 22, 1998, the IRS published proposed regulations regarding adequate disclosure of gifts on gift tax returns. Extensive written comments responding to the Federal Register notice were receive ...

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 ...

A Gift for Taxpayers and FLPs?

The Tax Court in this gift tax case has issued the first guidance on some of the tax issues facing family limited partnerships (FLPs).

IRS publishes final regulations for "adequate disclosure" of gifts

Responding to proposed gift tax regulation comments, on Dec. 3, 1999, the Internal Revenue Service published final regulations for the Adequate Disclosure of Gifts (64 Federal Register 67767). The ...

Kerr v. Commissioner (I)

At issue is the valuation of the FLP interests for federal gift tax purposes.

Taxpayers Transferred FLP Interests in Form and Substance

The Tax Court has issued the first guidance on some of the tax issues facing family limited partnerships (FLPs) in this gift tax case.

FLP’s Liquidation Provisions Must Be Considered When They Are Not More Restrictive Than State Law

The Tax Court granted the Kerrs' motion for summary judgment.

Partnership Assignee Interests Generate Discounts

"Partnership Assignee Interests Generate Discounts," Banoff, Sheldon I., Richard M. Lipton, and Burton W. Kanter , Journal of Taxation , April 1999, pp. 254-255. Family limited partnerships (FLPs ...

Are selling commissions deductible?

The September 1997 issue of BVU discusses the material contained in Partnership Spectrum regarding partnership discounts. Our firm has purchased the May/June issue each year and has found ...

Court Accepts Discounted Dividend Method, 40% Discount for Lack of Marketability

At issue is the value of petitioner's closely held stock in Crossroads Co., a reinsurance company domiciled in the Cayman Islands, that he gifted to his children on Jan. 1, 1992, and and Jan. 1, 1993.

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 ...

Dockery v. Commissioner

Issue is the value of petitioner's closely held stock in Crossroads Company, a reinsurance company domiciled in the Cayman Islands, that he gifted to his children.

Price Set Arbitrarily; Buy-Sell Price Not Controlling for Estate Tax

The issue is the effect, if any, of a buy-sell agreement on the value of shares of CamVic Corp. that are includable in the estate of Cameron W. Bommer (decedent).

Bommer Revocable Trust v. Commissioner

At issue is the effect, if any, of a restrictive stock agreement on the value of certain stock in CamVic Corp. that is includable in the Estate of Cameron W. Bommer.

Transfer of Property's Qualification for Gift Exclusion at Issue

At issue is whether or not the transfer of property in an irrevocable trust is eligible under section 2503(b) for the annual $10,000 gift exclusion with respect to each of 16 contingent beneficiaries of the trust.

Kohlsaat v. Commissioner

At issue is whether, in the computation of petitioner's Federal estate tax, decedent's inter vivos transfer of property to an irrevocable trust is eligible under section 2503(b) for the annual gift tax exclusion.

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