Subsidiaries' Licensing of IP Rights to Parents Created Sufficient Taxing Nexus
These consolidated cases concerned state income taxes of two corporations that did no business in Maryland but were subsidiaries of parents that did do business there.
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.
Lappo v. Commissioner
The issue for decision is the fair market value of interests in a family limited partnership that petitioner transferred in 1996.
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 ...
Bernier v. Bernier (2003)
Bernier v. Bernier (2003) US Massachusetts State Court Family Court Kaplan 5411 Grocery Stores 445110 Supermarkets and Other Grocery (except Convenience) Stores ...
E.J. Harrison and Sons, Inc. v. Commissioner
Issue is whether compensation paid to taxpayer's officer was reasonable compensation that was therefore deductible.
Entire Settlement Payment Is Purchase Price
One of the issues for the Tax Court was whether $4,856,922 of a $19,886,922 settlement made by Indeck Energy Services, Inc. to Michael P. Polsky was interest deductible by Indeck and recognizable as ordinary income to Polsky or whether it was part of the purchase price for shares of Indeck stock held by Polsky.
Tax Court Rules on Remand That IRC Section 2036 Applies
The original Tax Court ruling in this case was Estate of Strangi v. Commissioner, 115 T.C. No. 35 (U.S. Tax Ct. Nov. 30, 2000).
Hackl v. Commissioner (II)
Issue was whether restrictions on transfer in operating agreement meant that the gifted shares were "essentially without immediate value to the donees."
Brewer Quality Homes, Inc. v. Commissioner (I)
Issue is the extent to which amounts that petitioner paid to shareholder-officer are deductible as reasonable compensation under section 162(a)(1).
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.
Comptroller v. SYL, Inc.
Issue is whether there is a sufficient nexus between the State of Maryland and each subsidiary corporation to impose Maryland income tax.
Frontier Chevrolet Co. v. Commissioner
Issue is whether company's redemption of 75% of its stock was an “acquisition” within the meaning of IRC section 197, and whether the covenant not to compete needed to be amortized.
Boise Cascade Corp. v. United States
Issue is whether distributions to ESOP plan participants are deductible dividends.
Estate of Strangi v. Commissioner (III)
Issue on remand is whether the value of property transferred is includable in his gross estate pursuant to section 2036(a).
Indeck Energy Services, Inc. v. Commissioner
Issues are whether part of settlement payment constitutes interest deductible by Indeck and recognizable as ordinary income by petitioners, and whether penalties apply.
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").
Court Judges Assessment of Risk Factors, Marketability Discount Evidence
The issue in this consolidated case was the fair market value of two minority nonvoting stock interests in Schwan's Sales Enterprises Inc. (SSE), one as of Dec. 31, 1992 (date of gift) and the other as of Dec. 31, 1994 (date of charitable contribution).
Audio conference held on tax-affecting S corp earnings
As announced in this column last month, on August 13 an audio conference was held on tax-affecting S corporation earnings for the purpose of valuing stock. Bajaj: It is incorrect to tax-affect ...
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-affecting S corp earnings audio conference set for August 13
A groundbreaking audio conference featuring three outspoken commentators on whether, or under what circumstances S corporation earnings should be tax-affected has been scheduled for Tuesday, Aug. 13.
5th Circuit Affirms Kerr; Partnership Agreement Restrictions Do Not Preclude Marketability Discount
This case is the 5th Circuit Court of Appeals' review of the Tax Court case, Kerr v. Commissioner, 113 T.C. No. 30 (U.S. Tax Ct. Dec. 23, 1999), abstracted by Mel Abraham in the February 2000 issue of both Shannon Pratt's Business Valuation Update and Judges & Lawyers Business Valuation Update.
5th Circuit Remands Strangi to Consider § 2036 Claim
This case is the 5th Circuit's review of the Tax Court case, Estate of Strangi v. Commissioner, 115 T.C. No. 35 (U.S. Tax Ct. Nov. 30, 2000), abstracted in the January 2001 BVU.
Tax Court Accepts IRS Projections of Value Added Refund Income and Capital Expenditures
The issue in this case was the valuation of taxpayer Polack's gift of 1,040,000 shares of Zip Sort Inc. (ZSI) stock that he gifted to his children on Dec. 31, 1992 (260,000 of his nonvoting stock to each of his four children).