Estate of Tanenblatt v. Commissioner
Tax Court rejects taxpayer’s attempt to place in evidence a new appraisal regarding the decedent’s interest in an LLC whose principal asset was real estate by way of stipulation, finding he failed to qualify the appraiser as an expert and did not present ...
Tax Court Rejects GPCM, Dissects DCF in Valuing Minority LP Interest
Tax Court calculates value of a 41% family limited partnership (timberland assets) using a net asset value and DCF approach, the latter including a 25% DLOM and 16% discount rate, adjusted for unique risks.
Estate of Giustina v. Commissioner (I)
Tax Court calculates value of a 41% family limited partnership (timberland assets) using a net asset value and DCF approach, the latter including a 25% DLOM and 16% discount rate, adjusted for unique risks.
For Choosing Multiples & Comparables, the Data Really Do Matter
Court determines fair market value of limited partnership units in estate tax case, accepting net asset value and market approaches, with dispute focusing on measures and range of multiples for comparables ...
W.G. Anderson, et al. v. United States
Court determines fair market value of limited partnership units in estate tax case, accepting net asset value and market approaches, with dispute focusing on measures and range of multiples for comparables ...
Tax Court Finds 12% Minority Discount and 23% DLOM for Cash-Only FLP
In April 1999, Webster Kelley and his daughter and son-in-law (the Loudens) formed Kelley-Louden Business Properties LLC (KLBP LLC), and Kelley-Louden Ltd., a family limited partnership (KLLP).
Adoption of stale valuation date is abuse of discretion
One of the issues in this marital dissolution was the appropriate valuation date for valuing the couples’ business, Golight Inc., which had won a patent infringement suit against Walmart Stores Inc.
Disparity Between Valuations of Hedge Funds of Unlisted Securities Not Misleading by Itself; Self-Dealing Needed for Fraud
Beacon Hill Asset Management LLC (Beacon Hill), an investment manager of hedge funds that invested in mortgage-backed and related securities, allegedly overstated the net asset values (NAV) of three funds from March 2000 through September 2002 by as much as 61.22%.
Estate of Kelley v. Commissioner
In April 1999, Webster Kelley and his daughter and son-in-law ("the Loudens") formed Kelley-Louden Business Properties, LLC (KLBP LLC), and Kelley-Louden, Ltd., a family limited partnership (KLLP).
Fraternity Fund Ltd. v. Beacon Hill Asset Management LLC
One of the issues was whether Beacon Hill's valuations were fraudulent because they deviated from valuations done by independent appraisers/brokers.
Gardner v. Gardner
At issue in this marital dissolution appeal was the value of husband’s medical practice.
Parol evidence of components of sales price admissible for valuation
An issue raised in this marital dissolution concerned the husband's 50% interest in Z & G, Inc. The wife appealed the trial court's valuation of $105,653. During the divorce proceeding ...
Keath responds to judge's opinion in Smith
For obvious reasons, I was disappointed by Judge Gale’s opinion in Estate of Smith v. Commissioner . For perhaps less obvious reasons, however, the opinion caused me some concern. Few ...
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.
Tax Court Determines That Value Was 'Somewhere in the Middle' of Expert Opinions
The taxpayers' expert, Gregory Heebink, used the discounted cash flow (DCF) method and the guideline public company method.
Tax Court Accepts Negative Industry Risk Premium and Unique Combined Discount Matrix
The decedent, Helen Deputy, formed a family limited partnership comprised of 99% of a limited partnership interest retained by Deputy and two 0.5% general partnership interests, one held by Deputy and one held by her son.
Hess v. Commissioner
Taxpayers gave 10 shares of HII common stock (a 10% stockholder interest) to an irrevocable trust established for their daughter. Issue was the fair market value of the stock for gift tax p ...
Estate of Deputy v. Commissioner
Issue was the fair market value of a 19.99% interest of stock owned by an FLP, and court discussed negative industry risk premium and unique matrix for determining marketability discount.
Gross Estate Includes Date-of-Death Value of Assets Transferred to Family Limited Partnership
The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships: the Thompson Turner Family Limited Partnership ("Turner Partnership") and the Thompson Family Limited Partnership ("Thompson Partnership").
Estate of Thompson v. Commissioner
The issue in this case was whether decedent's gross estate included the value of interests in two family limited partnerships.
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.
Nontransferable Personal Goodwill Excluded From Value
The issue in this case was whether the trial judge erred in valuing of the husband's business. The husband operated his own telecommunications business, Champion Resources. The wife had wo ...
Court Accepts Evidence of Prior Sale Price of One-Half Interest Over Expert Valuations
One of the issues in this case was whether the trial court erred in determining that the value of Cardiz Tool and Machine (Cardiz) was $240,000 and awarding one-half of that value as marit ...
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.