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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."

Technical Advice Memorandum 9730004

PRIVATE RULING 9730004 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."

Technical Advice Memorandum 199938005

PRIVATE RULING 199938005 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) o ...

Revenue Procedure 98-34

SECTION 1. PURPOSE This revenue procedure sets forth a methodology to value for gift, estate, and generation-skipping transfer tax ("transfer tax") purposes certain compensatory stock options describ ...

Estate of Forbes v. Commissioner

Issue is fair market value of 42% and 42.9% undivided interests in two real estate parcels held by the QTIP, and what fractional discount should apply.

FLP trilogy a victory for taxpayers

As discussed in my December 2000 Editor's Column, I requested that several members of our Editorial Advisory Board provide me with comments regarding the recent Tax Court trilogy of FLP cases for a sy ...

Partnership discount info in a click

Partnership Profiles Minority Interest Discount Database , Partnership Profiles, Inc. , (800) 634-4614, Available online or CD-ROM. $295. &nbs ...

The IRS and Family Limited Partnerships—Issues and Opinions

n The IRS and Family Limited Partnerships—Issues and Opinions , Clay, Kimberly E. BizVal.com , Vol. 11, No. 3, 1999. Kimberly Clay explains that even though the IRS allows discounts for mino ...

IBA presents sample appraisal reports

Business Appraisal Reports Library , Vols. I and II , The Institute of Business Appraisers, Inc. , P.O. Box 17410, Plantation, FL 33318, (800) 299-4130, members: $499 (CD only-$399), nonmember: $59 ...

IRS cracks down on FLP discounts

"The IRS and Family Limited Partnerships Issues and Opinions," Clay, Kimberly E. , BizVal.com, Vol. 11, No. 3, 1999, Mercer Capital, (901) 685-2120, www.bizval.com. Kimberly Clay explains that even ...

ASA International Appraisers Conference Presentation Summaries

n Discount Settlements on Recent Family Limited Partnership Cases Curtis Kimball, ASA, CFA Willamette Management Associates Curtis Kimball discussed the increasingly popular medium for e ...

IRS audits family limited partnerships

A client of mine received the attached questionnaire from the Internal Revenue Service concerning preparations for a possible audit of his FLP. I am told that a number of FLPs have received ...

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 ...

Aggregation of estate interests

Assume Dad owns 100% of the general partnership interest in a limited partnership, and substantially all the limited partnership interests. The general partner has the unilateral right to s ...

Chicago Partnership Board debacle further hinders an already shrinking market for limited partnerships

Talk about finding out that the Chicago Partnership Board went under the hard way! Just ask Dr. Steve Gordon , who recently created a new company called Intelligent Automation Systems, based on his ...

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 ...

More Court Cases... Damages: Mallinga v. Harvey Family Medical Center

Plaintiff, a 25% shareholder in South Shore Medical Group, filed a complaint against Harvey Family Medical Center and South Shore Medical Group alleging that defendants diminished corporate assets resulted in personal gain to themselves and to the detriment of the plaintiff and that defendants failed to provide compensation to plaintiff for medical services he rendered to health maintenance organization (HMO) patients.

Mallinga v. Harvey Family Medical Center

At issue is the valuation of South Shore HMO Management Group, Inc, a foundation created by the plaintiff and the three individual defendant doctors.

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 ...

Useful variables for FLP values

I am sure that most of the readers of this newsletter have developed terminal disinterest in this ongoing "discussion" regarding the Kam et al study of syndicated LPs. However, I would lik ...

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 ...

72% limited partner in same position as minority stockholder

The thought that a minority interest discount is applicable to a partnerss ownership consisting of 1% general and 72% limited shares was introduced in the November 1995 issue of Business Val ...

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.

Fred Meyer v. Southeast, Chiles v. Robertson

At issue is whether the trial court erred in ordering defendants to purchase plaintiffs' interests in six closely held real estate companies at the price that the court established.

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