Entire Settlement Payment Is Purchase Price
One of the issues for the Tax Court was whether $4,856,922 of a $19,886,922 settlement made by Indeck Energy Services, Inc. to Michael P. Polsky was interest deductible by Indeck and recognizable as ordinary income to Polsky or whether it was part of the purchase price for shares of Indeck stock held by Polsky.
Comptroller v. SYL, Inc.
Issue is whether there is a sufficient nexus between the State of Maryland and each subsidiary corporation to impose Maryland income tax.
Frontier Chevrolet Co. v. Commissioner
Issue is whether company's redemption of 75% of its stock was an “acquisition” within the meaning of IRC section 197, and whether the covenant not to compete needed to be amortized.
Boise Cascade Corp. v. United States
Issue is whether distributions to ESOP plan participants are deductible dividends.
Indeck Energy Services, Inc. v. Commissioner
Issues are whether part of settlement payment constitutes interest deductible by Indeck and recognizable as ordinary income by petitioners, and whether penalties apply.
Court Judges Assessment of Risk Factors, Marketability Discount Evidence
The issue in this consolidated case was the fair market value of two minority nonvoting stock interests in Schwan's Sales Enterprises Inc. (SSE), one as of Dec. 31, 1992 (date of gift) and the other as of Dec. 31, 1994 (date of charitable contribution).
Tax Court Chooses Market Approach Over Asset Approach
The issue in this consolidated case involving the Caracci family was whether the value of the Sta-Home Health Agency Inc. (SHHA) and related entities transferred into S corporations exceeded the consideration paid.
Okerlund v. United States (I)
The issue in this consolidated case was the fair market value of two minority nonvoting stock interests in Schwan's Sales Enterprises, Inc.
Caracci v. Commissioner (I)
The issue was whether the value of the Sta-Home Health Agency, Inc. (SHHA) and related entities transferred into S corporations exceeded the consideration paid.
GETTING MONEY OUT OF THE FAMILY BUSINESS—AVOIDING CONFLICTS BETWEEN THE INCOME TAX AND THE TRANSFER TAX
Richard B. Robinson ALI-ABA Course of Study Materials: Estate Planning for the Family Business Owner , March 2001, Volume I This volume is divided into 22 chapters. Of particular interest to o ...
Gow v. Commissioner (II)
At issue is whether that the Tax Court improperly val-ued the plaintiff's shares of stock in Williamsburg Vacations, Inc. ("WVI") for tax purposes.
4th Circuit Affirms Gow v. Commissioner
This income tax case was appealed from the U.S. Tax Court. (The lower court case was abstracted in the May 2000 issues of both BVU and J&L ...
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 ...
IRC § 1033
LEXSTAT IRC sec. 1033 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 § 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 ...
9th Circuit Affirms Tax Court Reasonable Compensation Ruling
This decision affirms the Tax Court case abstracted in the December 1998 BVU, p. 5.
Thompson v. United States
At issue is the admittance of expert testimony.
Reliance on Expert Upheld
Plaintiff invested in Davenport Recycling Associates limited partnership, which turned out to be (without plaintiff's knowledge at the time) a sham transaction.
LabelGraphics, Inc. v. Commissioner (II)
At issue is the determination of reasonable employee compensation for deduction as an ordinary and necessary business expense.
IPO Price Assists in Determining Fair Market Value of Stock
The issue in this income tax matter is the fair market value of stock of Wedtech Corp. received by petitioner Mario Biaggi, but not reported as income on his 1983 income tax return.
Gow v. Commissioner (I)
At issue is the value of shares of stock of Williamsburg Vacations, Inc., awarded to the plaintiff.
Tax Court Values Bonus Compensation Stock, Applies Two-Tier Discounts
The valuation issue in this case pertained to the fair market value of two minority blocks of stock of Williamsburg Vacations Inc. (WVI) issued as bonus compensation to a shareholder/officer/director of a C corporation investment holding company in early 1989 and 1990.
Biaggi v. Commissioner
At issue is the fair market value of petitioners shares of stock in Wedtech Corp. for federal tax purposes.
READER SURVEY RESULTS 'More cases, more pages
We greatly appreciate your responses to the Reader Survey included with our October 1999 issue. Stacy and I have both reviewed every response received. We will incorporate the consensus of our readers ...
Exacto Spring v. Commissioner
At issue is the interpretation of tax law that allows a business to deduct from its income its "ordinary and necessary" business expenses.