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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.

Marketability discounts: using four measures of risk andadjusting for relative liquidity

Court cases are won with empirical evidence that is as nearly on point with the subject company as possible. In this article, Espen shows how companies with four specific risk measures (company size ...

Access to restricted stock studies

I have a question regarding the Editors Column feature in the February 2002 issue of Shannon Pratts Business Valuation Update. On page 3, middle column, under "Empirical research shows holding period important," Dr. Pratt makes the following statements about the restricted stock studies ...

Dr. Bajaj responds to Dr. Pratts February 2002 Editorial: Bajaj attacks restricted stock and pre-IPO discount studies; Pratt replies, defending studies, notes that debate may be semantic

In the last issue, Dr. Shannon Pratt critiqued my co-authored paper, Firm Value and Marketability Discounts, forthcoming in Journal of Corporation Law . 1, 2 I would like to take this op ...

From experts in valuation in each of nine industry groups to a takeoff on Survivor, AICPA BV Conference offers variety

The 2001 AICPA Business Valuation Conference held at the Venetian in Las Vegas December 2-4 was attended by 840 people (by the way, the Venetian served the best conference food that I've ever experienced).

Panel challenges traditional levels of value chart at the 20th Advanced Business Valuation Conference

The 20th annual American Society of Appraisers (ASA) Advanced Business Valuation Conference was a huge success, despite attendance of only about 325 compared to pre-Sept. 11 projections of 450 attende ...

What's new online

Ordering online now available at BVResources.com sm We are excited to announce that we have revamped our BVResources.com sm Web site and enabled the electronic ordering feature in our onlin ...

What's New Online

At BVLibrary.com sm The What's New section at BVLibrary.com sm is free and contains links to the Definition of the Week, Shannon's Tip of the Week, What's Happening, and Sale of the Month.

FMV to release its restricted stock study

Bringing Sanity to Marketability Discounts: A New Data Source, Espen Robak and Lance S. Hall , Valuation Strategies , July/August 2001, pp. 6-13, 45-46. Over the years, several approaches h ...

What's new online at BVLibrary.com

BVLibrary is a website designed with the business valuation professional in mind. It offers instant access to the latest business valuation research ...

BVR provides access to more marketability discount data

BVR announces the addition of Lance S. Hall to the Editorial Advisory Board of Judges & Lawyers Business Valuation Update and the addition of the FMV Restricted ...

Buy-Sell Agreements Fail Lauder II Test and Are Considered Testamentary Devices

This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.

Discounts and premiums must be supported with empirical data

In my April 2001 Editor's Column I discussed the treatment of marketability discounts in court cases, and briefly touched on empirical data to support those discounts. This column is a follow-up and includes an expanded discussion of the empirical studies available not only for marketability discounts, but for control premiums and minority discounts as well.

BV online library a valuable resource

A resource that is often overlooked by lawyers in their research and preparation of a case is the BV online library, accessible at BVLibrary.com . The staff at Business Valuation Resources has spent considerable time in recent months expanding the content and improving the look and functionality of BVLibrary.com.

Estate of True v. Commissioner

1Cases of the following petitioners are consolidated herewith: Jean D. True, docket No. 3408-98 and Estate of H.A. True, Jr., Deceased, H.A. True, III, Personal Representative, docket No. 3409-98. T.C. Memo. 2001-167 UNITED STATES TAX COURT ESTATE OF H.A. TRUE, JR., DECEASED, H.A. TRUE, III, PERSONAL REPRESENTATIVE, AND JEAN D. TRUE, ET AL.1, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 10940-97, 3408-98, Filed July 6, 2001. 3409-98. Buford P. Berry, Emily A. Parker ...

Buy-Sell Agreements Are Testamentary Devices

This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.

Buy-Sell Agreements Do Not Control for Estate Tax Purposes

The Tax Court considered whether buy-sell agreements controlled the value of the business interests the decedent held for estate and gift tax purposes.

Marketability discounts frequently a big money appraisal controversy

The applicability and/or magnitude of discounts for lack of marketability often are a large, if not the largest, money issue in a disputed business valuation. Lawyers should know enough about marketability discounts to make at least a preliminary judgment about their own and the opposing expert's justification as to the applicability or lack if it, and if applicable, justification as to the magnitude.

Tax Court Considers QMDM and Restricted Stock Studies in Determining Discount for Lack of Marketability

In November 1992, the Petitioners gifted shares of St. Edward Management Co. (the "Company") common stock to their children.

Janda v. Commissioner

In November 1992, the Petitioners gifted shares of St. Edward Management Company (the "Company") common stock to their children. Each gift represented approximately 5.3% of the outstanding shares of common stock. St. Edward Management Co. owned 94.6% of the common stock of the Bank of St. Edward (the Bank), a bank located in a small agricultural community in Nebraska.

Yes, restricted stock studies do matter after 1990

I read the May 2000 edition of Business Valuation Update with interest. I was specifically attracted to the guest article that discussed restricted stock discount studies.

Restricted stock discounts decline as result of 1-year holding period

This article addresses the changes in the marketplace for restricted securities that have occurred since 1990 and the impact that those changes have had on the overall level of discounts for lack of marketability for these securities.

Estate of Smith v. Commissioner

At issue is the value of Smith's shares of stock in two companies, Jones Farm Inc., and First National Bank of Waverly, as of her death.

Court Accepts Taxpayer's 76% Discount on Farm Corporation

The estate in this case held minority interests in two companies: Jones Farm Inc. (JFI) (33% ownership of common stock) and in the First National Bank of Waverly (FNBW) (12% of common stock).

The oxymoron of "control, marketable"

When we use the terms "marketable" or "nonmarketable" in business appraisal, we typically are referring to minority interests. Yet, some people apply the expression "marketable" or "nonmarketable" to controlling interests, where the distinction seems meaningless.

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