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Revenue Ruling 59-60

Rev. Rul. 59-60 SECTION 2031. - DEFINITION OF GROSS ESTATE 26 CFR 20.2031-2: Valuation of stocks and bonds. (Also Section 2512.) (Also Part II, Sections 811 (k), 1005, Regulations 105, Section 81.

Technical Advice Memorandum 9736004

PRIVATE RULING 9736004 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) of the ...

Technical Advice Memorandum 9842003

PRIVATE RULING 9842003 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) o ...

Tax Court Considers QMDM and Restricted Stock Studies in Determining Discount for Lack of Marketability

In November 1992, the Petitioners gifted shares of St. Edward Management Co. (the "Company") common stock to their children.

Financial and Estate Planning Techniques: Q&A, CCH

Financial and Estate Planning, Issue 505, December 15, 2000 This insightful article, in question and answer format, draws on the knowledge of members of the CCH Financial and Estate Planning A ...

Janda v. Commissioner

In November 1992, the Petitioners gifted shares of St. Edward Management Company (the "Company") common stock to their children. Each gift represented approximately 5.3% of the outstanding shares of common stock. St. Edward Management Co. owned 94.6% of the common stock of the Bank of St. Edward (the Bank), a bank located in a small agricultural community in Nebraska.

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.

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