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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 ...

More Good News on Estate and Gift Valuation

In this interview with Owen G. Fiore , an estate planning attorney with the Fiore Law Group, CCH, asks Fiore about the new IRS adequate disclosure regulations and the recent case of Kerr v. Commissi ...

Adequate Disclosure of Gifts

FEDERAL REGISTER Vol. 64, No. 232 Rules and Regulations DEPARTMENT OF THE TREASURY Internal Revenue Service (IRS) 26 CFR Parts 20, 25, 301 and 602 [TD 8845] RIN 1545-AW20 Adequ ...

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