5th Circuit Upholds Tax Court’s Characterization of Interest and Discount Rulings
5th Circuit affirms Tax Court’s ruling that decedent’s transferred interest is limited partner, not an assignee, interest; appeals court says estate’s related challenge to Tax Court’s valuation reflects disagreement with characterization of interest, not value computation; valuation holds up.
Estate of Streightoff v. Commissioner (II)
5th Circuit affirms Tax Court’s ruling that decedent’s transferred interest is limited partner, not an assignee, interest; appeals court says estate’s related challenge to Tax Court’s valuation reflects disagreement with characterization of interest, not value computation; valuation holds up.
Demystifying the Complex World of Discounts for Lack of Marketability (Part 2)
This is part 2 of the DLOM webinar from 2/12/2020. 25%? 35%? 45%? What’s the deal with discounts for lack of marketability? Pasquale Rafanelli dives into what DLOMs are, when they should be applied, and how to apply them. Learn about the different types of approaches and methods that valuation experts can use to quantify the DLOM, along with practical pros and cons of each approach and method. Part 2 discusses the analytical approaches and ...
Demystifying the Complex World of Discounts for Lack of Marketability (Part 1)
Please note: This is a rebroadcast. 25%? 35%? 45%? What’s the deal with discounts for lack of marketability? Pasquale Rafanelli dives into what DLOMs are, when they should be applied, and how to apply them. Learn about the different types of approaches and methods that valuation experts can use to quantify the DLOM, along with practical pros and cons of each approach and method. This session focuses on benchmark study approaches and security-based approaches. Please note ...
Demystifying the Complex World of Discounts for Lack of Marketability
25%? 35%? 45%? What's the deal with discounts for lack of marketability? Pasquale Rafanelli dives into what DLOMs are, when they should be applied, and how to apply them. Learn about the different types of approaches and methods that valuation experts can use to quantify the DLOM, along with practical pros and cons of each approach and method.
5th Circuit Upholds Tax Court’s Characterization of Interest and Discount Rulings
In estate tax dispute, Tax Court agrees with IRS that decedent transferred limited partner interest, not assignee interest, to revocable trust; under partnership agreement, limited partner had rights not available to assignee; court rejects discount for lack of control and adopts IRS’ DLOM rate.
Estate of Streightoff v. Commissioner (I)
In estate tax dispute, Tax Court agrees with IRS that decedent transferred limited partner interest, not assignee interest, to revocable trust; under partnership agreement, limited partner had rights not available to assignee; court rejects discount for lack of control and adopts IRS’ DLOM rate.
In Memory of Tax Court Judge David Laro
BVR is very sad to note that the eminent David Laro, a senior judge of the United States Tax Court, passed away on September 21. Valuators in particular looked up to Judge Laro for his unique understanding of the field of valuation and the role it plays in many tax cases.
In memory of Tax Court Judge David Laro
BVR is very sad to note that the eminent David Laro, a senior judge of the United States Tax Court, passed away on September 21.
Expert Dubbed "Unpersuasive" Rebuts Judge Laro's Rejection
Dear Shannon: I enjoyed speaking with you on the telephone and I appreciate your taking the time to review the Kaufman case. I have enclosed copies of the case, I have enclosed copies of the case, my initial valuation report of the subject interest as of April 14, 1994, and the supplemental report I prepared at Judge Laro's instruction before trial which addresses the lack of marketability selection specifically in the context of 10 factors mentioned in the Mandelbaum case.
Expert dubbed "unpersuasive" rebuts Judge Laro's rejection
I have reviewed the write up of Estate of Kaufman in the May issue of your newsletter, and I am very concerned that it unfairly portrays me as having not done a credible valuation because it takes Judge Laro's criticisms of my report at face value.
Peracchio v. Commissioner
Issues were appropriate discount for lack of control and discount for lack of marketability to apply in valuing gifts of family limited partnership interests.
Laro gives words of advice to BV experts
Judge David Laro of the U.S. Tax Court spoke at the 1999 AICPA Business Valuation Conference held in Las Vegas Dec. 5-7. He gave us insight into the Tax Court's views on valuation issues and what the ...