Kimbell v. US
At issue is the transferral of assets for an interest in partnership (operated by decedent's son) was a "bona fide" sale or not, thus incurring Section 2036 consideration.
Estate of Blount v. Commissioner (I)
The issue in this estate tax case was the value of decedent’s interest in a closely held company on the date of his death.
Polack v. Commissioner (II)
Earnings for the relevant valuation date determined after the valuation deemed irrelevant because a "prospective buyer could not have known" at that time ...
Robert v. United States
Issue in this gift tax case was whether IRS summonses should be quashed due to improper ex parte communications between the IRS Appeals Office and Examination Division.
Okerlund v. United States (II)
Events after the donation date, though foreseen in Dr. Pratt's valuation do not constitute reversiible error on the part of the Claims court for rejecting the valuation.
Capital Blue Cross v. Commissioner
At issue was the value of intangible assets for loss deductions.
The Charles Schwab Corporation v. Commissioner
Petitoner demonstrates it could determine the useful life of customer accounts it acquired after purchasing "Rose & Co." and therefore amortize them.
Estate of Hillgren v. Commissioner
At issue is the validity of discounts applied taking into consideration a business loan agreement.
Estate wins 2036 (a) challenge; FLPs did more than "recycle value"`
The only issue in these consolidated cases was whether assets owned by each of five family limited partnerships (FLPs) were includible in the gross estates of Mr. and Mrs. Stone under I.R.C.
DLOM Major Issue; Tax Court 'Splits the Baby'
At decedent’s death, she owned 3,276 shares of Royal Bancshares Inc. (RBI), or 5.09% of the outstanding RBI shares.
Estate of Abraham v. Commissioner (I)
At issue is the inclusion of certain properties in the gross estate which decedent had transferred while alive but from which retained generated income.
Grossly Inflated Sale Price, Nonrecourse Financing, and Negative Cash Flows Add Up to a Tax Shelter Not Engaged in for Profit
The issue was whether taxpayer was entitled to an $18,956 deduction related to his limited partnership interest for 1981 and whether he was liable for a valuation overstatement.
Estate of Green v. Commissioner
DLOM supported by restricted stock studies upheld while neither expert's minority interest discounts are upheld for lack of supporting analysis (therefore higher discount used).
Court Accepts Analogy of Outside Board Chair for Reasonable Compensation Case
The issue in this case was whether the company could deduct amounts paid to an officer-shareholder as reasonable compensation during the tax years at issue.
Tax Court displeased with all experts’ DLOC and DLOM analyses
The primary issues in this gift tax case were the appropriate discounts for lack of control and lack of marketability to apply to gifted and sold interests of a family limited partnership.
9th Circuit Affirms Tax Court; Noncompete Must Be Amortized Over 15 Years, Not Life of Agreement
Redemption was an “acquisition” within the meaning of IRC section 197 because Frontier regained possession and control over 75% of its stock.
Redemptions of ESOP Shares Were Deductible Dividends
The question of whether the distributions to plan participants are deductible dividends depends on who owned the convertible preferred stock when the redemptions took place.
Court Uses Raw Data From Bajaj Study to Determine DLOM
The only issue in this case was the fair market value of gifted family limited partnership (FLP) interests.
Estate of Cook v. Commissioner
At issue is the classification of a lottery prize issued in annual payments as a private annuity, thereby being valued using annuity tables (by the Tax Court) and thus without discounts.
5th Circuit Considered the Valuation of Lottery Payments
The U.S. Court of Appeals considered whether deviation from the annuity tables in Sec. 7520 was warranted in the valuation of a lottery prize.
Estate of Stone v. Commissioner
At issue is the inclusion of assets of five various family limited partnerships in the gross estates of Mr. and Ms. Stone under section(s) 2036 and 2044.
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.
Walford v. Commissioner
The overvaluation of an "emergency management system" resulted in the Commissioner disallowing a deduction made on the basis of the value of that asset. Subsequent sale showed act ...
Tax Court, Frustrated by Inadequate Data, Inscrutable Analyses, Bases Reasonable Compensation on RMA Ratios
The issue in this case was the reasonableness of compensation paid to the shareholder and primary officer of Brewer Quality Homes Inc. (Brewer).
7th Circuit Affirms Tax Court; Gifts Were of Future Interests
This opinion is the 7th Circuit Court of Appeals’ ruling on appeal from the Tax Court opinion of Hackl v. Commissioner, 118 T.C. 279 (U.S. Tax Ct. 2002).