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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.

Court Awards 30% Discount for Lack of Marketability

The taxpayer's motion for administrative cost recovery was the basis of this case.

Thompson, L v. Commissioner

At issue is the valuation of the plaintiff's stock in harwood sawmill company for federal gift tax purposes.

'Safe Harbor Rate' Not Adequate to Present Value Note for Gift Taxes; Circuits Disagree on Issue

Taxpayer transferred assets in return for a promissory note bearing interest at the then current "safe harbor" interest rate, which was below the prevailing market rate.

Minority Share Gifts: Court Finds 30% Discount for Lack of Marketability

The parties stipulated to freely traded minority interest values, so the only issue was the discount for lack of marketability.

Schusterman v. United States

At issue is the taxpayers arguement that their use of the six percent safe harbor rate under I.R.C. 483 prevents the IRS from using the prevailing market interest rate to determine the dis ...

Mandelbaum v. Commissioner

At issue is the amount of discount for lack of marketability that should be applied to determine the fair market value of certain shares of stock owned by some or all of petitioners.

Saltzman v. Commissioner

One of the issues was the fair market value of the family trusts' MBI stock at the time of the recapitalization.

Estate of Simpson v. Commissioner

At issue is the valuation of stock for gift tax purposes.

LeFrak v. Commissioner

At issue is the valuation of real estate property transferred to petitioners and whether petitioners are entitled to a discount for minority interest and lack of marketability in valuing the transferred interests.

Estate of Bruce v. Commissioner

Issue is whether, as a result of sale and redemption of stock of closely held corporation, Shirley A. Bruce made a taxable gift to her son and daughter-in-law, and if so, in what amount.

Moore v. Commissioner

Issues are value of interests in a partnership transferred as gifts and whether petitioners are liable for additions to tax for valuation understatement under section 6660.

Moore v. Commissioner

At issue in this case was the size of the discount to be applied to the valuation of a family held cattle and farming partnership.

Messing v. Commissioner

At issue is the valuation of stock gifted by the petitioner.

Central Trust Co. v. United States

At issue is the refund of federal gift taxes and the valuation of stock in a metal container manufacturer.

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