Sale of Nonprofit Facility Results in Inurement to Buyers; Court Refuses to Receive IRS Expert's Report in Evidence
According to the court, "The primary issue for decision is whether petitioner's tax-exempt status should be revoked."
Attorneys discuss case involving actuarial tables
Madden, Robert E., and Hayes, Lisa H.R. "Taxpayer Was Entitled to Rely on Actuarial Tables Despite Terminal Illness" Estate Planning, July 1998, pp. 268-271. This article discusses in some detai ...
Anclote Psychiatric Center v. Commissioner (II)
The primary issue is whether petitioner's tax-exempt status should be revoked, and whether the sale of its hospital in May 1983 was for less than fair market value.
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 ...
Family Limited Partnerships: Let's get ready to rumble!
The surge in popularity of family limited partnerships ("FLPs") over the past two years has provided both problems and opportunities for the valuation analyst. Due to the significant impact that these ...
ESOP conference addresses whether appraiser may be a fiduciary
At The ESOP Association's Valuation Advisory Committee meeting May 14, Jared Kaplan , a well-known ESOP attorney with McDermott, Will & Emery , said, "If you are a financial advisor to a fiduc ...
Partnership between appraiser and tax attorney
SP: Owen, I heard you say recently, The IRS has adopted the hyena pack' approach to transfer tax audits and tax litigation, believing there is tax abuse in the FLP area; What do you mean by t ...
Fiore advocates cooperation
In the past few issues of Business Valuation Update, there has been much coverage of FLP valuation, due to a combination of developing appraisal methodology and IRS stepped-up challenges of ...
Court Forced to Reach Conclusion Based on Weak Evidence
The issue in this case is the value of minority shares of Kosman, Inc., a family holding company owning shares of stock of small banks.
Kosman v. Commissioner
At issue is the value of petitioner's stock in Kosman that she gave to her children.
Trapped-in capital gains affects real-world value
An ongoing issue in gift and estate tax valuation is whether, or the extent to which, the liability for unrealized capital gains on appreciated assets should be reflected in valuation of a stock or pa ...
Article critiques the Tax Court's decision and experts' avidence in the Mandelbaum case
Hall, Lance S. and David M. Eckstein, "Ten Easy Steps to Determine Discounts: Fact or Fiction?" Article forthcoming in December issue of the CEB Estate Planning and California Probate Re ...
Limited partnership unit sales show large discounts from net asset value
This article focuses primarily on discounts for limited partnership interests, and also mentions discounts from net asset value (NAV) for companies in corporate form, detailing a few of the authors' own experiences in reaching settlements with the IRS.