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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.

Estate of Branson v. Commissioner of Internal Revenue

At issue is the fair market value of decendent's stock acquisitions.

Backlog of Willing Buyers Offsets Marketability Discount

The primary issue in this estate tax matter is the fair market value of 12,889 shares of Savings Bank of Mendocino County (Savings) stock, and 500 shares of Bank of Willits (Willits) stock, owned by decedent on the date of his death.

Restricted stock discounts, 1991-95

We're very pleased that Bruce chose Business Valuation Update for the initial publication of this latest in a long series of restricted stock discount studies.I think it's particularly useful that he empirically identifies three factors that impact the magnitude of the discount for lack of marketability.

Quantifying marketability discounts

I am in the process of completing my demonstration reports for my CBA. I used a 30% LOM discount after deriving a value for a closely held, small business using the Ibbotson build up method.

Minority Share Gifts: Court Finds 30% Discount for Lack of Marketability

The parties stipulated to freely traded minority interest values, so the only issue was the discount for lack of marketability.

Mandelbaum v. Commissioner

At issue is the amount of discount for lack of marketability that should be applied to determine the fair market value of certain shares of stock owned by some or all of petitioners.

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